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Latest Tax News

Court of Appeal on FNs and APNs—exhaust representations procedure before making judicial review claim (R (oao M Sport) v HMRC)

Court of Appeal on FNs and APNs—exhaust representations procedure before making judicial review claim (R (oao M Sport) v HMRC)

The following Tax news provides comprehensive and up to date legal information on Court of Appeal on FNs and APNs—exhaust representations procedure before making judicial review claim (R (oao M Sport) v HMRC)

Substantial shareholding exemption denied (M Group Holdings Ltd v HMRC)

Substantial shareholding exemption denied (M Group Holdings Ltd v HMRC)

The following Tax news provides comprehensive and up to date legal information on Substantial shareholding exemption denied (M Group Holdings Ltd v HMRC)

Share for share treatment available despite tax avoidance purpose (Euromoney Institutional Investor plc v HMRC)

Share for share treatment available despite tax avoidance purpose (Euromoney Institutional Investor plc v HMRC)

The following Tax news provides comprehensive and up to date legal information on Share for share treatment available despite tax avoidance purpose (Euromoney Institutional Investor plc v HMRC)

Taxation of contractor loans (Hoey v HMRC)

Taxation of contractor loans (Hoey v HMRC)

The following Private Client news provides comprehensive and up to date legal information on Taxation of contractor loans (Hoey v HMRC)

Featured Tax content

What is an intangible fixed asset?

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...

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

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...

SDLT—deeds of rectification

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...

Bank levy

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...

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

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

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

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

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

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...
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Produced in partnership with Ali Kazimi and Chris Orchard of Hansuke Consulting Limited 12th Jan
tag iconIn-house
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...
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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

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

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

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

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...
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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

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...
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9th Nov
Practice notes

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....
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9th Nov
Practice notes

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...
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9th Nov
Practice notes

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...
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9th Nov

Most recent Internationally mobile employees content

Practice notes

UK employment tax issues for cross-border employment

Given the ever increasing global mobility of employees, employers could be regularly required to understand and comply with numerous legislative...
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Produced in partnership with Darren Oswick of Simmons & Simmons 9th Apr
Practice notes

Internationally mobile employees with employment-related securities

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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Produced in partnership with Jeremy Edwards of Baker McKenzie and Gill Murdoch 9th Apr
Practice notes

Practical guidance on the taxation of share options for internationally mobile employees

This Practice Note summarises the taxation of internationally mobile employees and directors in relation to securities options (Options) charged to...
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Produced in partnership with Lewin Higgins-Green of FTI Consulting 9th Apr
Practice notes

Internationally mobile employees with securities options

IntroductionThis Practice Note discusses the taxation of internationally mobile employees and directors in relation to securities options (options)...
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Produced in partnership with Jeremy Edwards of Baker McKenzie and Gill Murdoch 9th Apr
Practice notes

Internationally mobile employees and employment-related securities (pre-6 April 2015) [Archived]

ARCHIVED: This Practice Note has been archived and is not maintained.Following recommendations of the Office of Tax Simplification and an HMRC...
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9th Apr
Practice notes

The UK tax treatment of dual contracts [Archived]

ARCHIVED: This Practice Note has been archived and is not maintained.One of the features of the UK employment income tax rules has long been to afford...
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Produced in partnership with Darren Oswick of Simmons & Simmons 9th Apr
Practice notes

Internationally mobile employees and securities options (pre-6 April 2015) [Archived]

ARCHIVED: This Practice Note has been archived and is not maintained.Following recommendations of the Office of Tax Simplification and an HMRC...
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9th Apr
Practice notes

The statutory residence test—overseas workday relief

Overseas Workday Relief (OWR) is a relief from UK income tax for certain non-domiciled individuals, who have elected to be taxed on the remittance...
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Produced in partnership with Lisa Spearman of Mercer & Hole 9th Apr
Practice notes

The structure of the statutory residence test

The UK’s first formal tax residency test for individuals known as the statutory residence test (SRT) took effect on 6 April 2013. Before this, whether...
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Produced in partnership with Lisa Spearman of Mercer and Hole and Emma Loveday of Wedlake Bell LLP 9th Apr
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...
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Produced in partnership with Laura Allwright of Simmons & Simmons and Darren Oswick of Simmons & Simmons 15th Feb
tag iconCOVID-19
Q&As

What are the key potential tax and legal implications of having a non-UK director on the board of directors of a UK company?

Before introducing a non-UK tax resident individual as a director of a UK company, the company should obtain advice from UK and non-UK tax advisers to...
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29th Nov

Popular documents

LEXISNEXIS

Written basis of plea and Newton hearings

When defendants are guilty, they have a choice to plead guilty or to put the prosecution to proof. When they plead guilty they may benefit from a reduction in their sentence as a result, see Practice Note: Credit for guilty plea. However, the Sentencing Council's overarching guidelines on reduction

LEXISNEXIS

Directors’ remuneration

Company directors are not, by virtue only of their office as director, automatically entitled under company law to remuneration for services as a director or to reimbursement of expenses incurred in rendering such services. Power to pay directors remuneration for their services will need to be

LEXISNEXIS

Double insurance and contribution

Overlapping insurance policesThere are various reasons why an insured may end up with overlapping insurance cover, whether deliberately or otherwise.Examples include the situation where the insured takes the benefit of other insurance arranged by another party or where, in the commercial world, risk

LEXISNEXIS

Breach of statutory duty

This Practice Note considers claims for damages for breach of statutory duty. For guidance on claims for damages for a negligent breach of duty of care outside a statutory duty, see Practice Notes:•Negligence—when does a duty of care arise?•Negligence—when is the duty of care breached?Breach of