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Latest Tax News

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)

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)

FTT agrees with HMRC’s methodology for calculating output tax assessments (Jupiter Asset Management Group Ltd)

The following Tax news provides comprehensive and up to date legal information on FTT agrees with HMRC’s methodology for calculating output tax assessments (Jupiter Asset Management Group Ltd)

FTT allows unilateral credit for US withholding tax when treaty relief did not apply (Aozora GMAC Investments v HMRC)

The following Private Client news provides comprehensive and up to date legal information on FTT allows unilateral credit for US withholding tax when treaty relief did not apply (Aozora GMAC Investments v HMRC)

Featured Tax content

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

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

Management buyouts—summary of tax issues for management

A management buyout, or MBO, involves the acquisition of a business by its existing management team usually with the help of private equity financing....

Clause—tax gross up—commercial agreements

1 Withholding and grossing up 1.1 All sums payable under this [Agreement] by or on behalf of any party (for the...

Practice notes

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...

9th Nov

Practice notes

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...

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

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...

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...

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...

9th Nov

In-house

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...

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...

Produced in partnership with Philip Rutherford 12th Jan

Practice notes

Schemes of reconstruction defined

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...

9th Nov

Practice notes

FATCA in the UK—the UK:US Intergovernmental Agreement: an outline

Coronavirus (COVID-19): HMRC has stated in its International Manual that if a financial institution cannot meet the FATCA reporting deadline of 31 May...

Produced in partnership with Ali Kazimi and Chris Orchard of Hansuke Consulting Limited 12th Jan

In-house

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...

Produced in partnership with Eloise Walker of Pinsent Masons 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:...

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...

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...

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...

Produced in partnership with Martin Wilson 12th Jan

Practice notes

SDLT—deeds of rectification

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...

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...

Produced in partnership with Anne Fairpo of Temple Tax Chambers 12th Jan

Most recent Earnings and benefits content

Practice notes

Tax issues on the provision of loans to employees or directors

Companies sometimes provide directors or employees with low interest (or interest-free) loans as part of the reward package or on specific occasions...

9th Apr

Practice notes

Taxation of payments for restrictive covenants or undertakings

Restrictive covenants or undertakingsThese are undertakings given by employees during employment or on termination which restrict their conduct or...

Produced in partnership with Sam Whitaker of Shearman & Sterling 9th Apr

Practice notes

Employment-related loans—defined

Specific rules in the benefits code in ITEPA 2003, Part 3 apply to 'employment-related loans' and, in certain circumstances, impose income tax and...

9th Apr

Practice notes

How employment income is taxed—concept of general earnings

The UK has a comprehensive code for the taxation of employment income. This Practice Note deals with the basic principles of income tax on employment...

9th Apr

Practice notes

How employment income is taxed—benefits and the residual liability provisions

The residual liability provisions are the back-stop of the benefits code, providing a means of calculating the value of a benefit provided to an...

9th Apr

Practice notes

Taxation of tips and commission payments

FORTHCOMING CHANGE: it was revealed in the Queen’s Speech on 14 October 2019 that the government intends to table legislation, the Employment...

9th Apr

Practice notes

How employment income is taxed—non-cash earnings or benefits

In addition to cash earnings, such as wages or salaries, many reward packages include non-cash items, such as the provision of a car, health insurance...

9th Apr

Practice notes

Writing off loans to directors or employees

Companies sometimes provide loans to directors or employees as part of the reward package or on specific occasions to help the individual meet...

9th Apr

Practice notes

Bonus schemes

IP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit transition/implementation period entered into following the UK’s...

7th Apr

Practice notes

Malus and clawback

FORTHCOMING CHANGE: On 18 March 2021, it was announced that the government was launching a consultation on wide-ranging reforms to modernise the...

Produced in partnership with Nick Hipwell, Sarah Ferguson and Chris Baker of DLA Piper 24th Mar

Q&As

Coronavirus (COVID-19)—what are the potential tax consequences of working remotely, including cross-border employment tax issues?

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...

Produced in partnership with Laura Allwright of Simmons & Simmons and Darren Oswick of Simmons & Simmons 15th Feb

COVID-19

Precedents

Client letter explaining the employee and employer tax consequences of staff entertainment and gifts to employees and directors

[Insert client’s address]Income tax treatment of staff entertainment and gifts to employees and directors1Purpose of this letterThis letter explains...

Produced in partnership with Victoria Kirsch of Baker McKenzie 8th Jan

Q&As

When does the UK tax earnings of non-UK resident employees who are employed by non-UK employers?

As a general rule, an employee is subject to income tax in the UK on his general earnings if he is resident in the UK or he is carrying out employment...

29th Nov

Q&As

What is the income tax liability on scholarship income when received by an employee?

Scholarship income is one of many types of income which are exempt from income tax. The exemption to income tax is set out in section 776 of the...

29th Nov

Earnings and benefits

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Latest Tax News

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)

FTT agrees with HMRC’s methodology for calculating output tax assessments (Jupiter Asset Management Group Ltd)

FTT allows unilateral credit for US withholding tax when treaty relief did not apply (Aozora GMAC Investments v HMRC)

Featured Tax content

Tax considerations on a loan agreement—the tax indemnity clause

International movement of capital

Management buyouts—summary of tax issues for management

Clause—tax gross up—commercial agreements

Most recent Earnings and benefits content

Popular documents

Contractual damages—pecuniary losses

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

Directors’ remuneration

Issue of redeemable shares

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