Companies and corporation tax

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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
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
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
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
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
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 Companies and corporation tax content

Q&As
We have assumed that the company is UK resident and that the dividend is not being paid between companies that are members of the same group for tax...
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15th Feb
Q&As
It is assumed that the seller and the buyer of the property are third parties acting at arm’s length and that the property transferred between them is...
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15th Feb
Q&As
A reorganisation of a company’s share capital should be tax neutral for its shareholders. This is because the essential feature of a reorganisation is...
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Produced in partnership with Mary Ashley of Old Square Tax Chambers 15th Feb
Q&As
In answering this Q&A, we have assumed that the person in question is a UK resident and domiciled person carrying on a sole trade (ie not in...
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15th Feb
Q&As
Most demergers (liquidation demergers, capital reduction demergers and indirect statutory demergers) include a step under which the shareholders of...
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15th Feb
Q&As
We have assumed that all relevant parties are UK resident companies.We have also assumed the following scenario:•X Ltd owes money to Y Ltd, but not as...
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15th Feb
Q&As
A director’s liability for a company’s unpaid tax debtsAs a general principle, a limited company is liable for its own debts and the company’s...
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15th Feb
Q&As
This Q&A considers whether exploitation of intellectual property (IP) can be a trading activity so that it is a ‘trading company’ for the purposes of...
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15th Feb
Q&As
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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15th Feb
Q&As
It is in the context of the old advance corporation tax regime that FII is most often referred to, not least because of the very long running case...
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15th Feb
Q&As
Entrepreneurs’ relief (ER) is a complex relief for individuals and certain trusts from capital gains tax in respect of disposals of certain business...
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15th Feb
Q&As
In this Q&A we assume that the owner of the property is a non-UK resident individual and is not calculating trade profits on the cash basis.For...
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15th Feb
Q&As
Bare trusts and CGTA transfer to a nominee or a bare trustee, under which the beneficial title does not move, is ignored for capital gains tax (CGT)...
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15th Feb

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