Loss reliefs

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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
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: 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
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
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 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
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
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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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
Practice notes
This Practice Note:•explains:◦the purpose of the tax indemnity clause that is normally found in a loan agreement, and◦that the standard drafting of...
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9th Nov

Most recent Loss reliefs content

Practice notes
FORTHCOMING CHANGE: Finance Bill 2021 amends the definition of a change of ownership so that the ‘wider’ definition (referred to below), that...
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26th Apr
Practice notes
A UK company that has incurred a loss in its UK property business for an accounting period can, in general, use that loss by:•setting it against total...
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9th Apr
Practice notes
A capital gain that would otherwise result in a charge to tax may be reduced or eliminated if the taxpayer has made capital losses and is able to set...
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9th Apr
Practice notes
All companies within the charge to corporation tax can deduct qualifying charitable donations from their total profits, after all other deductions...
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9th Apr
Practice notes
The intangible fixed asset regimeCompanies within the charge to corporation tax are generally subject to the intangible fixed assets regime (the IFA...
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Produced in partnership with Anne Fairpo of Temple Tax Chambers 9th Apr
Practice notes
What is a loss?The general concept of 'loss' is not defined in corporation tax legislation. The natural meaning of loss in the context of a business...
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9th Apr
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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24th Mar
Practice notes
FORTHCOMING CHANGE relating to carry-back of losses: As announced at Spring Budget 2021, for accounting periods ending between 1 April 2020 and 31...
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12th Mar

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