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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
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
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
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
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
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

Most recent Companies and corporation tax content

Q&As
The purpose of an election under section 198 of the Capital Allowances Act 2001 is to allow the buyer and seller of a property to elect jointly to...
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15th Feb
Q&As
Firstly, the capital gains tax (CGT) relief is only in respect of the disposal of shares originally awarded with an unrestricted market value at...
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15th Feb
Q&As
This Q&A assumes that the joint venture will take the form of a joint venture company (JVC) rather than a partnership or a contractual joint...
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15th Feb
Practice notes
A person wishing to set up a new company has the following options:•they can incorporate a new company in accordance with the Companies Act 2006 (CA...
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15th Feb
Precedents
1Capital allowances—for use where the Seller has claimed plant and machinery allowances and the parties will enter into a s 198/s 199 election on...
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Produced in partnership with Martin Wilson 14th Feb
Precedents
[Team Leader][insert HMRC address][insert date]Application for clearances in advance under [section[s] 138[ and 139(5)] Taxation of Chargeable Gains...
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14th Feb
Precedents
1Capital allowances1.1In this clause 1:CAA 2001•means Capital Allowances Act 2001Fixtures•means those items forming part of the Tenant’s Works which...
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Produced in partnership with Martin Wilson 14th Feb
Practice notes
This Practice Note contrasts and compares the principal features of the two most commonly utilised transaction structures for the acquisition of a UK...
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Produced in partnership with Julian Henwood of Gowling WLG 14th Feb
Practice notes
The buyer may fund the acquisition by way of:•cash: from its internal cash resources (or those of its parent or other group company)•debt financing:...
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14th Feb
Practice notes
This Practice Note examines the key steps and issues that a UK incorporated company will need to take and consider prior to making an application for...
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14th Feb
Practice notes
With effect from 1 January 2016, banking companies and building societies have been required to pay a surcharge of 8% on their taxable profits...
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Produced in partnership with Andrew Loan of Fieldfisher LLP 12th Feb
Practice notes
Taxation and insolvencyThere are relatively few specific rules governing the UK taxation of companies that are subject to insolvency procedures. The...
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Produced in partnership with David L. Irvine, Nathan Langford of Kirkland & Ellis International LLP and Philip Ridgway of Temple Tax Chambers 11th Feb
Practice notes
What is an enhanced capital allowance?An enhanced capital allowance (ECA) is a tax relief for businesses on their investments in certain categories of...
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Produced in partnership with Begonia Filgueira FIEMA of Acuity Legal 9th Feb
Practice notes
Some company acquisitions that involve a corporate buyer will be structured so that the consideration payable is the issue of new shares and/or loan...
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9th Feb
Practice notes
Capital allowances are the means by which a taxpayer can obtain a deduction when calculating taxable profits for some, but not all, forms of capital...
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Produced in partnership with Martin Wilson 9th Feb
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 9th Feb
Q&As
Companies HouseThe statutory rules in relation to overseas companies are set out in Part 34 of the Companies Act 2006 (CA 2006) and the Overseas...
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9th Feb
Practice notes
FORTHCOMING CHANGE relating to property rich collective investment vehicles and certain investors: HMRC consulted until 16 December 2020 on draft...
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9th Feb

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