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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
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 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
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 Coronavirus (COVID-19) 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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21st Jan
Practice notes
STOP PRESS (9/11/20): On 30 October 2020, HMRC published 11 guidance notes giving further details of eligibility for the Job Support Scheme (JSS) and...
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19th Jan
Practice notes
ARCHIVED: This archived Practice Note is not maintained and is for background information only.UPDATE (5/11/20):The Chancellor of the Exchequer, Rishi...
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19th Jan
Practice notes
UPDATE (15/12/20): On 24 November 2020, the Treasury Direction in relation to the third SEISS grant (SEISS 3) was published, and the related HMRC...
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19th Jan
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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19th 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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18th 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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18th Jan
Practice notes
Effective preparation of bundles is an essential element of a smooth, orderly hearing and something which practitioners should keep in clear focus as...
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Produced in partnership with Ross McLeod, Christopher Humby, Leo Kitchen and Damian Curran of Quinn Emanuel Urquhart & Sullivan UK LLP 18th 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
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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13th Jan
Q&As
There are a range of issues that could arise for transfer pricing purposes, due to the impact of coronavirus (COVID-19).Intra-group contractsThe...
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Produced in partnership with Kapisha Vyas of Simmons & Simmons and Tomoko Ikawa of Simmons & Simmons 8th Jan
Q&As
As a result of measures to slow down the spread of coronavirus (COVID-19), many countries including the UK are in lockdown. For employees, this often...
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Produced in partnership with Laura Allwright of Simmons & Simmons and Darren Oswick of Simmons & Simmons 8th Jan
Q&As
Government recommendations on social distancing, self-isolation in the case of sickness, and business closures has resulted in many typical business...
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Produced in partnership with Bryn Reynolds of Simmons & Simmons and Jo Crookshank of Simmons & Simmons 8th Jan
Q&As
Any restrictions on travel imposed by the coronavirus (COVID-19) may impact on corporate tax residency if businesses do not take care to recognise the...
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Produced in partnership with Martin Shah 8th Jan
Q&As
The temporary increase in the nil rate band for SDLT applies to transactions with an effective date that falls within the period from 8 July 2020...
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6th Jan
Q&As
The Crown Dependencies of Jersey, Guernsey and the Isle of Man, and the Overseas Territories of Bermuda, Cayman Islands and British Virgin Islands...
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29th Nov
Q&As
FORTHCOMING CHANGE: proposed temporary relaxation of the statutory residence test: On 9 April 2020, a letter from the Chancellor to the Chair of the...
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29th Nov
Q&As
This Q&A takes account of the HMRC guidance for employers: Claim for your employees' wages through the Coronavirus Job Retention Scheme as at 15 April...
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25th Nov

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