Brexit and tax

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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 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 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
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
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
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
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
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 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
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 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
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
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
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
Stamp duty land tax (SDLT) ceased to apply to any land transaction involving any interests in or over land in Scotland from 1 April 2015. From that...
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9th Nov
Practice notes
Part 8 of the Corporation Tax Act 2009 (CTA 2009) is a specific corporation tax regime that applies exclusively to the gains and losses of intangible...
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Produced in partnership with Anne Fairpo of Temple Tax Chambers 12th Jan

Most recent Brexit and tax content

Practice notes
Brexit—UK tax consequencesThis Practice Note sets out the areas of UK tax law that are affected by the UK's exit from the European Union (EU) (Brexit)...
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15th May
Practice notes
What does IP completion day mean for Tax?As of exit day (11 pm on 31 January 2020), the UK ceased to be an EU Member State and no longer participates...
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15th May
Practice notes
Brexit and tax—the continued application of EU lawThis Practice Note is about the extent to which EU law continues to apply to the UK’s tax rules...
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15th May
Practice notes
Brexit—Tax—Legislation trackerFor a spreadsheet listing all tax-related Brexit Statutory Instruments and Acts, click below.The Brexit Tax Legislation...
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15th May
Precedents
Retained EU law—training materialsThese training materials consist of template PowerPoint slides that can be used as the basis of one or more training...
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12th May
Practice notes
Brexit legislation tracker 2017–19 [Archived]ARCHIVED: This Practice Note has been archived and is not maintained. It tracks the progress of UK...
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12th May
Practice notes
Brexit legislation trackerThis Practice Note tracks the progress of UK legislation introduced as part of the legislative project associated with the...
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12th May
Practice notes
Brexit timelineOn 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...
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12th May
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 29th Apr
Q&As
None, provided the loan agreement is in Loan Market Association (LMA) standard form.The tax gross-up and indemnity clauses (and their accompanying...
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Produced in partnership with Eloise Walker of Pinsent Masons 15th Apr
Q&As
Retained EU law is a legal concept describing EU-derived legislation, rights and principles the UK plans to preserve in UK law after Brexit. It is a...
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Produced in partnership with Mathias Cheung of Atkin Chambers 15th Apr
Practice notes
The UK’s formal withdrawal from the EU took effect at 11 pm on 31 January 2020 (exit day). At this point, the withdrawal period under Article 50 TEU...
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Produced in partnership with Kieran Laird of Gowling WLG 15th Apr
Q&As
The term ‘transition or implementation period’ is used in the Agreement on the withdrawal of the United Kingdom of Great Britain and Northern Ireland...
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8th Apr
Q&As
For the purposes of this Q&A we have focused on the matters directly relevant to World Trade Organization (WTO) rules as they relate to trade in goods...
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8th Apr
Q&As
Any material amendment to loan terms could mean it becomes a new loan for FATCA purposes. For this to be the case, the modification has to be...
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Produced in partnership with Ronnie Brown of Burness Paull 8th Apr
Q&As
There are two schools of thought on how Brexit may prevent the Financial Transactions Tax (FTT) proposals from affecting the UK. The first is a policy...
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Produced in partnership with Hilary Barclay of Burges Salmon 8th Apr
Q&As
In order to answer this question it is necessary to understand the effect of the VAT Directive in UK law prior to Brexit, before going on to consider...
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25th Mar
Practice notes
Background—EU law in the UKPre-exit dayThe European Communities Act 1972 (ECA 1972) was introduced and intended to give effect to the UK's obligations...
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Produced in partnership with Dr. Kieran Laird of Gowling WLG 16th Mar
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 12th Mar
Q&As
As with most aspects of Brexit, we are yet to ascertain the precise impact of the UK’s impending exit from the EU on cross-border VAT and Customs...
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Produced in partnership with Andrew Rimmer of BVC Associates Ltd 15th Feb

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