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Latest Tax News

Supreme Court finds taxpayer had not made deliberate inaccuracy and that staleness is not relevant to discovery (HMRC v Raymond Tooth)

Supreme Court finds taxpayer had not made deliberate inaccuracy and that staleness is not relevant to discovery (HMRC v Raymond Tooth)

The following Private Client news provides comprehensive and up to date legal information on Supreme Court finds taxpayer had not made deliberate inaccuracy and that staleness is not relevant to discovery (HMRC v Raymond Tooth)

Tax weekly highlights—13 May 2021

Tax weekly highlights—13 May 2021

The following Tax news provides comprehensive and up to date legal information on Tax weekly highlights—13 May 2021

Contracts—‘Reasonable detail’ in notice clause determined by business purpose (Dodika Ltd and others v United Luck Group Holdings Ltd)

Contracts—‘Reasonable detail’ in notice clause determined by business purpose (Dodika Ltd and others v United Luck Group Holdings Ltd)

The following Commercial news provides comprehensive and up to date legal information on Contracts—‘Reasonable detail’ in notice clause determined by business purpose (Dodika Ltd and others v United Luck Group Holdings Ltd)

Taxpayer’s Ramsay argument fails before the Court of Appeal (Khan v HMRC)

Taxpayer’s Ramsay argument fails before the Court of Appeal (Khan v HMRC)

The following Tax news provides comprehensive and up to date legal information on Taxpayer’s Ramsay argument fails before the Court of Appeal (Khan v HMRC)

Featured Tax content

Tax considerations on a loan agreement—the tax indemnity clause

Tax considerations on a loan agreement—the tax indemnity clause

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...

International movement of capital

International movement of capital

The international movement of capital rules should be considered whenever:•any non-UK tax resident subsidiary (referred to in this note as a foreign...

Value shifting

Value shifting

The value shifting rules are anti-avoidance provisions. They are similar to the rules applying to depreciatory transactions in that they target the...

Property authorised investment funds (PAIFs)—summary

Property authorised investment funds (PAIFs)—summary

The regime for property authorised investment funds (PAIFs, or as HMRC use in regulations and their published guidance, Property AIFs)) was introduced...

Practice notes

EIS funds, including approved knowledge-intensive funds

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

Types of lending

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

VAT treatment of damages and compensation payments

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
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Practice notes

Direct tax treatment of damages and compensation payments

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

What is a tax determination?

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

Tax considerations on a loan agreement—the tax gross up clause

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

Section 198 and 199 elections on transactions involving real estate

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

Capital reduction demergers

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

Why have a tax covenant?

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

VAT on composite supplies

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

Plant and machinery allowances—definition of plant and machinery

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 for foreign tax

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

Bank levy

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

VAT—triangulation

Brexit: This Practice Note contains information on subjects impacted by the UK’s withdrawal from the EU. The Taxation (Cross-border Trade) Act 2018,...
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Produced in partnership with John Fuszard of Sagars Accountants Ltd 12th Jan
Practice notes

Property holding structures—direct tax treatment of a Jersey property unit trust (JPUT)

FORTHCOMING CHANGE relating to property rich collective investment vehicles and certain investors: HMRC is consulting until 16 December 2020 on draft...
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9th Nov
Practice notes

What is an intangible fixed asset?

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 Current issues content

Practice notes

Taxation of cryptoassets

Taxation of cryptoassetsThis Practice Note is about the UK tax treatment of cryptoassets, which is used in this Practice Note as a generic term for...
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Produced in partnership with Etienne Wong of Old Square Tax Chambers 15th May
Practice notes

Key dates for tax lawyers: 2021 and beyond

Key dates for tax lawyers: 2021 and beyondCoronavirus (COVID-19):As a result of coronavirus (COVID-19) many events have been postponed and cancelled...
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15th May
Practice notes

Image rights—protection, exploitation and taxation

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 6th May

Popular documents

Law of the arbitration proceedings—curial law or lex arbitri (England and Wales)

Law of the arbitration proceedings—curial law or lex arbitri (England and Wales)

This Practice Note considers the law governing the procedural law of arbitration proceedings (the curial law or lex arbitri) and how it is determined under the law of England and Wales (England and English are used as convenient shorthand).The procedural law of the arbitral proceedingsThe procedural

Escrow accounts and escrow agreements

Escrow accounts and escrow agreements

This Practice Note examines why parties involved in a construction project may enter into an escrow agreement (or escrow deed) to set up an escrow account. It looks at the benefits of paying funds into escrow, how an escrow account operates and the provisions typically found in an escrow

Recklessness in criminal cases

Recklessness in criminal cases

What is recklessness?In respect of some statutory offences and common law crimes the prosecution are required to prove a mental element of recklessness on the part of the defendant.Recklessness means unjustified risk taking on the part of the accused.Prior to the House of Lords decision in Re G

Declaratory relief of planning decisions

Declaratory relief of planning decisions

A declaratory judgment is a judgment identifying the rights, duties or obligations of one or more parties in a dispute. It is legally binding, but does not order any action by a party. A court may issue it alone or in conjunction with some other relief such as an injunction and can be granted on an