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...
Coronavirus (COVID-19): HMRC has stated in its International Manual that if a financial institution cannot meet the FATCA reporting deadline of 31 May...
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...
Overdrafts, term loans and revolving credit facilitiesThree common types of loan facility are:•overdrafts•term loans, and•revolving credit facilities...
The international movement of capital rules should be considered whenever:•any non-UK tax resident subsidiary (referred to in this note as a foreign...
A limited company may buy back shares that it has in issue, provided certain conditions set out in the Companies Act 2006 (CA 2006) are met. This is...
This practice note:•explains the key CGT (shorthand for capital gains tax and corporation tax on chargeable gains) implications of a rights issue for...
This Practice Note explains the key stamp duty and stamp duty reserve tax (SDRT) implications of a rights issue; in particular, the stamp duty and/or...
Various tax incentives are available to individuals investing in unlisted shares and securities such as shares admitted to trading on AIM. AIM is one...
Since 28 April 2014, no stamp duty or stamp duty reserve tax (SDRT) is chargeable on a transfer of shares or securities that are:•admitted to trading...
Stamp duty is an ad valorem duty which applies to transfers of stock and marketable securities for consideration where the transfer is effected by a...
Individual savings accounts (ISAs) are tax-free funds in which UK residents can hold a range of different investments. Originally, these were cash or...
On a share buyback that is implemented by the company directly or through an intermediary acting as agent for the company, the standard tax treatment...
A private limited company will only buy back its own shares off-market pursuant to a share buyback contract, which will include provisions specifying...
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