Plant and machinery allowances are the most widely used form of capital allowance. Plant and machinery is often (wrongly) interpreted as if the terms...
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...
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:...
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...
It is standard market practice for loan agreements (also known as facility agreements), whether bilateral or syndicated, to:•prohibit a borrower from...
Coronavirus (COVID-19): HMRC has stated in its International Manual that if a financial institution cannot meet the FATCA reporting deadline of 31 May...
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...
Overdrafts, term loans and revolving credit facilitiesThree common types of loan facility are:•overdrafts•term loans, and•revolving credit facilities...
The regime for property authorised investment funds (PAIFs, or as HMRC use in regulations and their published guidance, Property AIFs)) was introduced...
A management buyout, or MBO, involves the acquisition of a business by its existing management team usually with the help of private equity financing....
The international movement of capital rules should be considered whenever:•any non-UK tax resident subsidiary (referred to in this note as a foreign...
Where a company acquires (or otherwise incurs capitalised expenditure upon) an intangible fixed asset that falls within the corporate intangible fixed...
The intangible fixed asset regimeCompanies within the charge to corporation tax are generally subject to the intangible fixed assets regime (the IFA...
Capital allowances are available for qualifying capital expenditure on know-how where the acquirer is not within the corporate intangibles tax regime...
Capital allowances are available and provide a deduction for capital expenditure on acquiring two particular types of intangible fixed asset:•patents...
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...
Groups of companiesA number of reliefs in respect of intangible fixed assets depend on membership of a group. For example, where there is a disposal...
The realisation of an intangible fixed asset will lead to a tax charge or deduction for the taxpayer company under the intangible fixed assets regime...
Transfers within a groupWhere an intangible fixed asset is transferred from one group member to another and the asset is within the intangible fixed...
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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