Dividends and distributions

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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
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
Brexit: As of exit day (31 January 2020) the UK is no longer an EU Member State. However, in accordance with the Withdrawal Agreement, the UK has...
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Produced in partnership with Martin Shah and Gary Barnett of Simmons & Simmons LLP 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
The reasons why a company might carry out a demerger, and the different ways in which a demerger may be structured, are described in Practice Notes:...
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Produced in partnership with Zoe Feller of Bird & Bird 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
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
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
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
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
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
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
Precedents
1 Withholding and grossing up 1.1 All sums payable under this [Agreement] by or on behalf of any party (for the...
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9th Nov
Practice notes
A management buyout, or MBO, involves the acquisition of a business by its existing management team usually with the help of private equity financing....
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9th Nov
Practice notes
The international movement of capital rules should be considered whenever:•any non-UK tax resident subsidiary (referred to in this note as a foreign...
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9th Nov
Practice notes
This Practice Note:•explains:◦the purpose of the tax indemnity clause that is normally found in a loan agreement, and◦that the standard drafting of...
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9th Nov

Most recent Dividends and distributions content

Practice notes
A dividend is a type of distribution made by a company to its members. n relation to the law and practice relating to distributions made by a company,...
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18th Jan
Practice notes
As further explained in Scope of distributions for tax purposes, distributions can be divided into four categories:•dividends—encompassing paragraph A...
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15th Jan
Practice notes
ARCHIVED: This Practice Note has been archived and is not maintained.The way in which individuals are taxed on distributions was substantially changed...
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15th Jan
Practice notes
This Practice Note covers the:•clearance procedure, and•administrative rules (enquiries, counteraction notices and appeals)relating to the...
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15th Jan
Practice notes
A non-small company is subject to corporation tax on a distribution received unless, amongst certain other requirements, the distribution falls within...
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15th Jan
Practice notes
As further explained in Scope of distributions for tax purposes, distributions can be divided into four categories:•dividends—encompassing paragraph A...
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15th Jan
Practice notes
As further explained in Practice Note: Scope of distributions for tax purposes, distributions can be divided into four...
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15th Jan
Practice notes
There are eight anti-avoidance provisions which prevent the application of one or more of the exempt classes of distribution for distributions...
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15th Jan
Practice notes
Alongside the concept of new consideration, which is further explained in Distribution key concepts—new consideration, the concept of repayment of...
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15th Jan
Practice notes
There are eight anti-avoidance provisions which prevent the application of one or more of the exempt classes of distribution for distributions...
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15th Jan
Practice notes
What is a dividend reinvestment plan and why do companies offer them?A dividend reinvestment plan (DRIP) is a plan under which a company (almost...
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15th Jan
Practice notes
Any dividend or other distribution of a company is subject to corporation tax unless that distribution is exempt.There are two sets of exemptions for...
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15th Jan
Practice notes
A non-small company is subject to corporation tax on a distribution received unless, amongst certain other requirements, the distribution falls within...
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15th Jan
Practice notes
What is a scrip dividend and why do companies make them?A scrip dividend, also referred to as a scrip or stock issue, a stock dividend or a scrip...
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15th Jan
Practice notes
A non-small company is subject to corporation tax on a distribution received unless, amongst certain other requirements, the distribution falls within...
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15th Jan
Practice notes
Any dividend or other distribution of a company received by a company within the charge to corporation tax is subject to corporation tax on income,...
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15th Jan
Practice notes
Although the most common type of distribution is a dividend paid by a company to its shareholders in respect of their shares (ie a distribution of...
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15th Jan
Practice notes
This Practice Note explains the rules that apply to distributions made to UK resident and domiciled individuals on or after 6 April 2016.The way in...
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15th Jan
Practice notes
ARCHIVED: This Practice Note has been archived and is not maintained.The way in which individuals are taxed on distributions was substantially changed...
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15th Jan
Practice notes
This Practice Note covers the transactions in securities (TiS) rules relating to the avoidance of both income tax and corporation tax.The TiS rules...
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7th Dec

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