Loan relationships

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VAT on composite suppliesSingle composite supplies vs multiple suppliesWhere a supply comprises a number of different elements with varying VAT...
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Produced in partnership with Martin Shah and Gary Barnett of Simmons & Simmons LLP 19th May
Practice notes
Commercial service charges—VAT implicationsThis Practice Note is about the VAT treatment of non-residential service charges. General positionService...
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Produced in partnership with Martin Scammell 19th May
Practice notes
Offshore receipts in respect of intangible property (ORIP)Since 6 April 2019, a person that is neither UK tax resident nor resident in a full treaty...
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19th May
Practice notes
FATCA in the UK—the UK:US Intergovernmental Agreement: an outlineIP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit...
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Produced in partnership with Ali Kazimi and Chris Orchard of Hansuke Consulting Limited 19th May
Practice notes
Tax considerations on a loan agreement—the tax gross up clauseIP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit...
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Produced in partnership with Eloise Walker of Pinsent Masons 19th May
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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19th May
Practice notes
Taxation of UK LLPsA UK limited liability partnership (LLP) is a body corporate for company law purposes, but is generally taxed as though it were a...
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19th May
Practice notes
Section 198 and 199 elections on transactions involving real estateThis Practice Note describes the law and practice relating to elections under...
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Produced in partnership with Martin Wilson 19th May
Practice notes
Loan capital exemption from stamp dutyDebt which:•qualifies as loan capital (whether it is short or long-term debt), and•satisfies further conditions...
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19th May
Practice notes
The Budget and Finance Bill processThe Budget is a Parliamentary event at which the Chancellor of the Exchequer makes important announcements relating...
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19th May
Practice notes
Capital reduction demergersThe reasons why a company might carry out a demerger, and the different ways in which a demerger may be structured, are...
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Produced in partnership with Zoe Feller of Bird & Bird 19th May
Q&As
Corporate redomiciliation—can a non-UK company redomicile into the UK?It is possible for a non-UK incorporated company to redomicile to the UK....
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19th May
Practice notes
Why have a tax covenant?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...
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19th May
Practice notes
R&D capital allowancesFORTHCOMING CHANGE: At Spring Budget 2021, the government announced a wide-ranging review of research and development (R&D)...
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Produced in partnership with Anne Fairpo of Temple Tax Chambers 19th May
Practice notes
Transfer of a trade under common ownershipSometimes the restructuring of a business will involve a company transferring an existing trade to a...
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19th May
Practice notes
SDLT group reliefFORTHCOMING CHANGE relating to FA 2008, Sch 36: In its Tax Information and Impact Note (TIIN) on freeports, the government announced...
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19th May

Most recent Loan relationships content

Q&As
A company pays its shareholders a dividend in specie of loan notes that were previously issued to the company. Is there a disposal of the loan notes...
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16th Aug
Q&As
Is there a disposal which creates a chargeable gain when a simple debt (ie not a security) is converted into a qualifying corporate bond by the issue...
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16th Aug
Q&As
Does a connected entity as defined in section 1122 of the Corporation Tax Act 2010 (CTA 2010) or an associated company with the meaning of section 449...
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16th Aug
Q&As
Where a discount on a bond is treated as disguised interest, does the deeming provision mean that income tax must be withheld at source from the...
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16th Aug
Q&As
Where interest on a loan is capitalised, does the capitalised interest become a capital gain or remain as income for UK tax purposes?We have assumed...
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16th Aug
Q&As
When would preference shares fall under the shares as debt rules and hence the dividend payments would fall to be taxed as debt as opposed to...
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16th Aug
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 Aug
Practice notes
Loan relationships—accounting framework and principlesA foundational principle of the loan relationships regime is that companies are taxed on their...
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15th Aug
Practice notes
Loan relationships—what are they?The loan relationships regime provides the rules for the taxation and relief of a company’s profits and losses from...
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15th Aug
Practice notes
Loan relationships—anti-avoidance: related transactions not at arm's lengthIP COMPLETION DAY: The Brexit transition period ended at 11pm on 31...
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15th Aug
Practice notes
Loan relationships—the main tax rulesThe loan relationships regime provides the rules for the taxation and relief of a company’s profits and losses...
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15th Aug
Practice notes
Corporate interest restrictionThe rules comprising the corporate interest restriction are lengthy and complex. To assist the reader, this Practice...
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15th Aug
Practice notes
Loan relationships—late-paid interestThe loan relationships rules in Part 5 of the Corporation Tax Act 2009 (CTA 2009) contain certain anti-avoidance...
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15th Aug
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 Aug
Practice notes
Loan relationships—anti-avoidance: counteracting avoidance arrangementsIP COMPLETION DAY: The Brexit transition period ended at 11pm on 31 December...
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15th Aug
Practice notes
Loan relationships—connected companies relationshipsSpecific rules exist within the loan relationships regime in Part 5 of the Corporation Tax Act...
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15th Aug
Practice notes
Taxation of loan relationships—intra-group transfersIP COMPLETION DAY: The Brexit transition period ended at 11pm on 31 December 2020. At this time...
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15th Aug
Practice notes
Loan relationships—impairment and debt releasesA foundational principle of the loan relationships regime is that the profits and losses to be brought...
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15th Aug
Practice notes
Loan relationships—impairment and debt releases: connected companiesA foundational principle of the loan relationships regime is that the profits and...
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15th Aug

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