Loan relationships

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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
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
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
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
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
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
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 Loan relationships content

Practice notes
Taxation of loan relationships—shares accounted for as liabilitiesA ‘loan relationship’ is defined as a money debt arising from the lending of money....
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15th May
Practice notes
Types of distribution—interest recharacterised as a distribution: special securitiesAlthough the most common type of distribution is a dividend paid...
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15th May
Practice notes
Taxation of loan relationships—accounting framework and principlesIP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit...
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15th May
Practice notes
Loan relationships—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
Taxation of loan relationships—impairment and debt releasesIP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit...
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15th May
Practice notes
Loan relationships—deeply discounted securitiesIP 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 loan relationships—impairment and debt releases: connected companiesA foundational principle of the loan relationships regime is that the...
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15th May
Practice notes
Loan relationships—anti-avoidance: foreign exchange gains and lossesIP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit...
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15th May
Practice notes
Taxation of loan relationships—late-paid interestIP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit...
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15th May
Practice notes
Taxation of loan relationships—intra-group transfersIP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit...
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15th May
Practice notes
Loan relationships—anti-avoidance: related transactions not at arm's lengthIP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the...
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15th May
Practice notes
Taxation of loan relationships—connected companies relationshipsSpecific rules exist within the loan relationships regime in Part 5 of the Corporation...
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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
Taxation of loan relationships—what are loan relationships?The loan relationships regime provides the rules for the taxation and relief of a company’s...
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15th May
Practice notes
Types of distribution—interest recharacterised as a distribution: non-commercial securitiesAlthough the most common type of distribution is a dividend...
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15th May
Practice notes
Loan relationships—anti-avoidance: unallowable purposesThe rule is that the credits (broadly, but not necessarily, profits) and debits (broadly, but...
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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
Taxation of loan relationships—the main rulesThe loan relationships regime provides the rules for the taxation and relief of a company’s profits and...
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15th May
Practice notes
Taxation of loan relationships—disguised interestA ‘loan relationship’ is defined as a money debt arising from the lending of money. However, this...
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15th May

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