Group relief

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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
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
This Practice Note describes the law and practice relating to elections under section 198 or 199 of the Capital Allowances Act 2001 (CAA 2001), which...
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Produced in partnership with Martin Wilson 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
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
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
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 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
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 value shifting rules are anti-avoidance provisions. They are similar to the rules applying to depreciatory transactions in that they target 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

Most recent Group relief content

Practice notes
Provisions in the Finance (No 2) Act 2017 (F(No 2)A 2017) made considerable reforms to the rules governing what companies can do with carried-forward...
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15th Jan
Practice notes
A company can surrender by way of group relief:•a trading loss•a capital allowance excess•a non-trading loan relationship deficit•qualifying...
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15th Jan
Practice notes
Why does it matter?A company that is a member of a group and has incurred any of the types of losses available for surrender by way of group relief...
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15th Jan
Practice notes
Consortium relief is the term used to describe an extension to the group relief rules that allows the surrender and claim of losses between companies...
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15th Jan
Practice notes
Conditions for claiming group reliefIf a company (the surrendering company) has a loss or other amount that can be surrendered for group relief in an...
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15th Jan
Practice notes
Why does it matter?It is common for corporate entities to operate within a group, ie several companies under common ownership. The basic UK...
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15th Jan
Practice notes
Consortium relief is an extension of the group relief rules to allow the surrender and claim of losses between companies that are not so closely...
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15th Jan
Practice notes
The maximum amount of group relief that a company (the claimant company) can claim in any given accounting period (the claim period) is broadly the...
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17th Dec
Practice notes
A company within a group can, in certain circumstances surrender a tax refund which is due to it to another member of that group. It can be to the...
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29th Nov
Precedents
This Agreement is made on [insert date]Parties1[Insert name of party] a company incorporated in England and Wales (under number [insert registered...
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29th Nov
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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