Derivative contracts

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Practice notes
The regime for property authorised investment funds (PAIFs, or as HMRC use in regulations and their published guidance, Property AIFs)) was introduced...
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Produced in partnership with Martin Shah of Simmons & Simmons LLP based on material originally written by Charles Goddard of Rosetta Tax LLP 12th Jan
Practice notes
The Enterprise Investment Scheme (EIS) is designed to encourage investment in smaller, higher-risk trading companies by offering a range of tax...
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9th Nov
Practice notes
Overdrafts, term loans and revolving credit facilitiesThree common types of loan facility are:•overdrafts•term loans, and•revolving credit facilities...
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9th Nov
Practice notes
A damages or compensation payment may attract VAT. This depends on exactly what the payment is for. If it is purely compensatory, it will be outside...
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9th Nov
Practice notes
Where a dispute is brought to an end by a payment of damages or compensation, whether under a court order or an out-of-court settlement agreement:•the...
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9th Nov
Practice notes
This Practice Note explains:•what a determination in respect of direct tax (ie a direct tax determination) is•when HMRC might issue a direct tax...
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Produced in partnership with Philip Rutherford 12th Jan
Practice notes
This Practice Note is about the meaning of a scheme of reconstruction for tax purposes.Tax neutrality is maintained where a company (company A) enters...
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9th Nov
Practice notes
Coronavirus (COVID-19): HMRC has stated in its International Manual that if a financial institution cannot meet the FATCA reporting deadline of 31 May...
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Produced in partnership with Ali Kazimi and Chris Orchard of Hansuke Consulting Limited 12th Jan
Practice notes
It is standard market practice for loan agreements (also known as facility agreements), whether bilateral or syndicated, to:•prohibit a borrower from...
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Produced in partnership with Eloise Walker of Pinsent Masons 12th Jan
Practice notes
It is market practice for a tax covenant, also known as a tax deed, to form part of the transaction documents in respect of a sale of all the shares...
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9th Nov
Practice notes
Plant and machinery allowances are the most widely used form of capital allowance. Plant and machinery is often (wrongly) interpreted as if the terms...
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Produced in partnership with Martin Wilson 12th Jan
Practice notes
Unilateral relief, like double tax relief, aims to relieve double taxation. Subject to certain conditions being satisfied and specific limits,...
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9th Nov
Practice notes
FORTHCOMING CHANGE: HMRC is consulting (13 July to 10 August 2020) on draft regulations to provide a deduction from a UK entity’s equity and...
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Produced in partnership with Charlotte Sallabank of Katten Muchin Rosenman UK LLP 12th Jan
Practice notes
Stamp duty land tax (SDLT) ceased to apply to any land transaction involving any interests in or over land in Scotland from 1 April 2015. From that...
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9th Nov
Practice notes
FORTHCOMING CHANGE relating to property rich collective investment vehicles and certain investors: HMRC is consulting until 16 December 2020 on draft...
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9th Nov
Practice notes
Part 8 of the Corporation Tax Act 2009 (CTA 2009) is a specific corporation tax regime that applies exclusively to the gains and losses of intangible...
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Produced in partnership with Anne Fairpo of Temple Tax Chambers 12th Jan

Most recent Derivative contracts content

Practice notes
Taxation of derivative contracts—what are derivative contracts?The derivative contracts rules are a self-contained regime governing the taxation of a...
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15th May
Practice notes
Taxation of derivative contracts—chargeable gains basis rulesThe general rule is that the profits and losses arising to a company from its derivative...
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15th May
Practice notes
Derivative contracts—anti-avoidance: unallowable purposesThe general rule is that:•the credits (broadly, but not necessarily, profits), and•debits...
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15th May
Practice notes
Derivative contracts—hedging: accountingIP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit transition/implementation period...
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15th May
Practice notes
Derivative contracts—hedging (periods of account beginning before 1 January 2015): elections to disapply Regulation 9IP COMPLETION DAY: 11pm (GMT) on...
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15th May
Practice notes
Derivative contracts—hedging: taxation (currency contracts and commodity and debt contracts)IP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks...
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15th May
Practice notes
Derivative contracts—anti-avoidance: counteracting avoidance arrangementsIP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit...
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15th May
Practice notes
Derivative contracts—hedging: taxation (basics)IP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit transition/implementation...
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15th May
Practice notes
Taxation of derivative contracts—the main rulesIP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit transition/implementation...
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15th May
Practice notes
Corporate interest restrictionFORTHCOMING CHANGE: Finance Bill 2021 contains two technical amendments to the corporate interest restriction (CIR)...
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15th May
Practice notes
Derivative contracts—hedging (periods of account beginning before 1 January 2015): elections to disapply Regulations 7 and 8IP COMPLETION DAY: 11pm...
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15th May
Practice notes
Derivative contracts—hedging: taxation (interest rate contracts)IP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit...
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15th May
Practice notes
Taxation of derivative contracts—embedded derivativesThis Practice Note does not constitute accounting advice and is not intended to be exhaustive in...
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15th May
Practice notes
Derivative contracts—anti-avoidance: transactions not at arm's length and foreign exchange gains and lossesIP COMPLETION DAY: 11pm (GMT) on 31...
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15th May
Q&As
Can an entity be a ‘connected [person]’ as defined in section 1122 of the Corporation Tax Act 2010 (CTA 2010) or an ‘associated company’ with the...
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29th Nov

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