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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
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
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
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 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 Current issues content

Practice notes
The government has announced a number of measures in response to the coronavirus (COVID-19) crisis either that relate specifically to the UK tax...
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12th Apr
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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9th Apr
Practice notes
Appeals and applications to the First-tier Tribunal and Upper Tribunal are both significantly affected by the coronavirus (COVID-19) pandemic. This...
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9th Apr
Practice notes
This Practice Note tracks the progress of UK legislation introduced as part of the legislative project associated with the UK’s withdrawal from the...
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9th Apr
Practice notes
This Practice Note considers the ‘flexible furloughing’, revised version of the Coronavirus Job Retention Scheme (CJRS) that applied between 1 July...
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9th Apr
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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9th Apr
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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9th Apr
Practice notes
This Practice Note displays the current status of the 15 action points of the Organisation for Economic Co-operation and Development (OECD)'s Base...
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9th Apr
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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9th Apr
Practice notes
CORONAVIRUS (COVID-19): There is a delay in processing correspondence (including returns and cheques) sent by post to the Welsh Revenue Authority...
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Produced in partnership with Andrew Evans 9th Apr
Practice notes
This tax 'tracker' tool displays the current status of both US FATCA and UK FATCA intergovernmental agreements (IGA).The tracker is split into five...
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9th Apr
Practice notes
ARCHIVED: This archived Practice Note is not being maintained. It tracked the passage of the Bill through Parliament to its publication as an Act, and...
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9th Apr
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 9th Apr
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 Andrew Mylne, Head of Non-Government Bills Unit, Scottish Parliament 9th Apr
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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8th Apr
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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8th Apr
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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8th Apr
Practice notes
This Practice Note summarises the key ways in which company filing and other administrative procedures have temporarily changed due to the coronavirus...
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8th Apr
Practice notes
This Practice Note provides an introduction to retained EU law. It provides an overview of the key definitions and concepts with reference to the...
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Produced in partnership with Dr. Kieran Laird of Gowling WLG 8th Apr
Practice notes
On 23 June 2016, the UK held a referendum on its membership of the EU, with a majority voting in favour of the UK leaving the EU. On 29 March 2017,...
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8th Apr

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