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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
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
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
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
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
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 Current issues content

Practice notes
This Tax tracker shows the current status of, and developments on, consultations (both formal and informal) conducted by the UK government (and other...
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15th Jan
Practice notes
Cryptoassets, exchange tokens, utility tokens and security tokensIt started with Bitcoin (see below). An avalanche of other non-traditional currencies...
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Produced in partnership with Etienne Wong of Old Square Tax Chambers 15th Jan
Practice notes
Land and buildings transaction tax (LBTT) replaced stamp duty land tax (SDLT) in Scotland with effect from 1 April 2015. This Practice Note provides...
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Produced in partnership with Ronnie Brown of Burness Paull 15th Jan
Practice notes
This Practice Note is about the extent to which EU law continues to apply to the UK’s tax rules (direct tax and VAT) following the end of the Brexit...
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15th Jan
Practice notes
CORONAVIRUS (COVID-19): Revenue Scotland is not processing paper returns due to COVID-19. Agents are encouraged to make returns through SETS (the...
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Produced in partnership with Ronnie Brown of Burness Paull 15th Jan
Practice notes
During the coronavirus (COVID-19) pandemic, the UK government announced a series of measures to support individuals and businesses that are adversely...
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15th Jan
Practice notes
The tracker is split into two main parts:•tracking by country, which is split down into:◦Wales◦Scotland, and◦Northern Ireland, and•tracking by tax,...
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15th Jan
Practice notes
CORONAVIRUS (COVID-19): the Coronavirus (Scotland) (No 2) Act 2020 received royal assent on 26 May 2020. This includes provisions at part 4 of...
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Produced in partnership with Ronnie Brown of Burness Paull 15th Jan
Practice notes
As of exit day (11 pm on 31 January 2020), the UK ceased to be an EU Member State and no longer participates in the political institutions and...
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15th Jan
Practice notes
FORTHCOMING CHANGE relating to PAIFs and CoACS: The Scottish government announced in its budget 2019–2020 that it intends to introduce two reliefs...
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Produced in partnership with Ronnie Brown of Burness Paull 15th Jan
Practice notes
ARCHIVED: This Practice Note has been archived and is not maintained.As of 31 January 2020 (exit day), the UK is no longer an EU Member State and its...
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Produced in partnership with Adam Cygan of University of Leicester 15th Jan
Practice notes
What is landfill disposals tax?Landfill disposals tax is an environmental tax administrated by the Welsh Revenue Authority.Since 1 April 2018,...
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Produced in partnership with Angus Evers of Shoosmiths 15th Jan
Practice notes
This tax tracker tool displays the current status and most recent developments of tax cases being heard by the Upper Tribunal (UT), the Court of...
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14th Jan
Practice notes
Coronavirus (COVID-19):As a result of coronavirus (COVID-19) many events have been postponed and cancelled at short notice. For more information on...
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14th 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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14th Jan
Practice notes
This Practice Note contains information on the Finance Act 2020 (FA 2020) which received Royal Assent on 22 July 2020. It is being retained for...
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14th Jan
Practice notes
The Budget is a Parliamentary event at which the Chancellor of the Exchequer makes important announcements relating to the national economy. This...
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14th 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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Produced in partnership with Kieran Laird of Gowling WLG 13th 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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13th Jan
Practice notes
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 entered an...
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Produced in partnership with JJ Shaw of Lewis Silkin LLP, Alex Kelham of Lewis Silkin LLP and Rob Meredith CTA of PKF Francis Clark 13th Jan

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