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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 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
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
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
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
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
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: This Practice Note contains information on subjects impacted by the UK’s withdrawal from the EU. The Taxation (Cross-border Trade) Act 2018,...
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Produced in partnership with John Fuszard of Sagars Accountants Ltd 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 Group relief content

Practice notes
Corporation tax loss relief for carried-forward lossesProvisions in the Finance (No 2) Act 2017 (F(No 2)A 2017) made considerable reforms to the rules...
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15th May
Practice notes
Surrender of tax refunds within a groupA company within a group can, in certain circumstances surrender a tax refund which is due to it to another...
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15th May
Practice notes
Priority between loss reliefs in loss making companiesFORTHCOMING CHANGE relating to carry-back of losses: As announced at Spring Budget 2021, for...
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15th May
Practice notes
Consortium reliefConsortium relief is an extension of the group relief rules to allow the surrender and claim of losses between companies that are not...
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15th May
Practice notes
Corporation tax group relief: claims procedure and paymentsConditions for claiming group reliefIf a company (the surrendering company) has a loss or...
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15th May
Practice notes
How much consortium relief can be surrendered and claimed?Consortium relief is the term used to describe an extension to the group relief rules that...
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15th May
Practice notes
How much group relief can be surrendered and claimed?The maximum amount of group relief that a company (the claimant company) can claim in any given...
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15th May
Practice notes
Group relief—types of losses that can be surrenderedA company can surrender by way of group relief:•a trading loss•a capital allowance excess•a...
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15th May
Practice notes
Group relief—loss relief groupWhy does it matter?It is common for corporate entities to operate within a group, ie several companies under common...
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15th May
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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