Companies and corporation tax

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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
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
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
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
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 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 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
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 Companies and corporation tax content

Practice notes
When a company that is resident outside the UK starts doing business in the UK, it will want to know whether and to what extent the activities of that...
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5th Feb
Practice notes
Coronavirus (COVID-19) IMPACT: Certain aspects of the PSC regime are affected by temporary measures introduced to mitigate the consequences of the...
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5th Feb
Practice notes
Why does it matter?It is common for corporate entities to operate within a group, ie several companies under common ownership. The basic UK...
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4th Feb
Practice notes
Companies which form a group for capital gains purposes are able to transfer assets to one another free of corporation tax on chargeable gains.Each...
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2nd Feb
Practice notes
Investors’ relief is a capital gains tax (CGT) relief introduced by Finance Act 2016, designed for individuals who invest in unquoted trading...
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Produced in partnership with Satwaki Chanda 2nd Feb
Practice notes
The UK has two approaches to taxing IP transactions:•the corporate intangibles tax rules: these apply to IP created or acquired by a company on or...
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Produced in partnership with Anne Fairpo of Temple Tax Chambers 2nd Feb
Practice notes
This Practice Note considers the tax treatment of transactions in intangible assets between related parties within the corporate intangible fixed...
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Produced in partnership with Anne Fairpo of Temple Tax Chambers 2nd Feb
Practice notes
When a sole trader (or an individual running a business as a partner in a partnership) decides to incorporate that business, he transfers the assets...
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29th Jan
Practice notes
IP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit transition/implementation period entered into following the UK’s...
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29th Jan
Practice notes
This Practice Note is part of the Share purchase transaction toolkit.As well as deciding whether the transaction should be structured as a share...
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28th Jan
Practice notes
Companies House has issued guidance for its customers, suppliers and employees on a number of temporary changes it has made to its usual procedures...
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28th Jan
Practice notes
BackgroundThis Practice Note considers the impact that the coronavirus (COVID-19) pandemic may have on the preparation and filing of a company’s...
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28th Jan
Practice notes
A limited company may buy back shares in itself, if certain conditions set out in the Companies Act 2006 (CA 2006) are met. This is known as a share...
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27th Jan
Practice notes
The corporate intangibles tax rules contain a number of provisions for relief from tax on the transfer of a business or trade These reliefs are...
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Produced in partnership with Anne Fairpo of Temple Tax Chambers 26th Jan
Practice notes
From April 2019, the profit fragmentation rules aim to prevent UK-resident individuals, including individual members of a partnership, and UK-resident...
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26th Jan
Practice notes
IntroductionWhere a company:•listed on the Official List of the Financial Conduct Authority and admitted to trading on the main market for listed...
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Produced in partnership with Chris McGaffin of Slaughter and May. 26th Jan
Practice notes
This Practice Note focuses on the key legal considerations when a rights issue is being carried out by a company either:•admitted to listing on the...
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Produced in partnership with James Ufland of Slaughter and May and Chris McGaffin of Slaughter and May 26th Jan
Practice notes
IntroductionThis Practice Note focuses on types of placings and certain matters that require consideration when a placing is being carried out by a...
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Produced in partnership with Chris McGaffin of Slaughter and May. 26th Jan
Practice notes
FORTHCOMING CHANGE: Finance Bill 2020–2021 will contain two technical amendments to the CIR rules to ensure the regime works as intended. The first is...
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26th Jan
Practice notes
A foundational principle of the loan relationships regime is that the profits and losses to be brought into account for corporation tax purposes on a...
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26th Jan

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