Plant and machinery allowances are the most widely used form of capital allowance. Plant and machinery is often (wrongly) interpreted as if the terms...
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...
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:...
It is standard market practice for loan agreements (also known as facility agreements), whether bilateral or syndicated, to:•prohibit a borrower from...
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...
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...
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...
The regime for property authorised investment funds (PAIFs, or as HMRC use in regulations and their published guidance, Property AIFs)) was introduced...
A management buyout, or MBO, involves the acquisition of a business by its existing management team usually with the help of private equity financing....
The international movement of capital rules should be considered whenever:•any non-UK tax resident subsidiary (referred to in this note as a foreign...
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...
[Insert client’s address]Income tax treatment of staff entertainment and gifts to employees and directors1Purpose of this letterThis letter explains...
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...
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...
Companies sometimes provide directors or employees with low interest (or interest-free) loans as part of the reward package or on specific occasions...
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...
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