This Practice Note is about capital allowance-related pre-contract enquiries on a property transfer. It applies to the grant of a new property interest (eg a lease) as...
This Practice Note sets out how the capital allowances rules interact with the rules relating to: • capital gains tax, including corporation tax on chargeable gains (CGT)...
FORTHCOMING CHANGE relating to a corporate capital loss restriction: Finance Bill 2019–20 will introduce a corporate capital loss restriction (CCLR), limiting companies’...
Entrepreneurs' relief is a capital gains tax (CGT) relief designed to encourage individuals to set up and expand their own businesses. Provided that the conditions are...
This Practice Note provides an overview of issues that are likely to be encountered by an English lawyer when advising a seller or a buyer in a cross-border private M&A...
When employees are transferred along with the business in which they work pursuant to the Transfer of Undertakings (Protection of Employment) (TUPE) Regulations 2006, SI...
Although the Taxation of Chargeable Gains Act 1992 (TCGA 1992) does not set out how to calculate a capital gain (referred to in the legislation as a chargeable gain), the...
The sale of a company's business can be structured as either: • a sale of the business assets owned by the current owner, including goodwill (an asset sale), or • a sale...
This Practice Note is about roll-over relief for capital assets, which is a deferral of capital gains tax, or corporation tax on chargeable gains, for certain disposals...
A company can obtain roll-over relief, under the intangible fixed assets regime (IFA regime) to defer the tax charge on gains on realisation of intangible fixed assets...
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 are relevant to...
The sale of a company's business can be structured as either: • a sale of assets owned by the company (an asset sale), or • a sale of shares in the company by its...
In an asset sale, the buyer selects and purchases from the seller only those assets and liabilities it wishes to acquire. Sometimes, an asset sale is the sale of an...
The conditions for a transfer of a business to be treated as a transfer of a going concern (a TOGC) are set out in Practice Note: VAT—what is a transfer of a business as...
This Practice Note is about the issues that arise on a transfer of a going concern involving land and buildings. A transfer of a going concern (TOGC) has two distinct...
The sale of a 'business' is really a sale of assets bundled together. VAT would therefore be charged on the transfer of each asset in accordance with the normal rules, ie...
A UK based purchaser of an overseas business will need to consider the following tax issues: • the potential overseas and UK tax costs associated with the acquisition •...
A non-UK based purchaser of a UK business (or UK-headquartered business) will need to consider the following tax issues: • the UK costs associated with the acquisition •...
The realisation of an intangible fixed asset will lead to a tax charge or deduction for the taxpayer company under the intangible fixed assets regime (IFA regime). This...