Equity capital markets

Understand the intricate tax implications associated with equity capital markets through our expert guidance. The resources we provide are crafted to assist you in advising clients on strategic transactions, including IPOs and secondary offerings, while ensuring adherence to the latest tax regulations and updates. Stay at the forefront with insights specifically tailored to the dynamic relationship between taxation and equity financing.

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Latest Tax News

FTT confirms HMRC’s £20.5 million tax charge holding taxpayer had English domicile of choice (Griffin v HMRC)

FTT confirms HMRC’s £20.5 million tax charge holding taxpayer had English domicile of choice (Griffin v HMRC)

Tax analysis: In Sir John Griffin v HMRC, the First-tier Tax Tribunal (FTT) held that the taxpayer’s Irish domicile of origin had been replaced by...

Tax weekly highlights—24 September 2026

Tax weekly highlights—24 September 2026

This week's edition of Tax weekly highlights includes: (1) News Analyses on the FTT decisions in Environmental Services Ltd on research and...

FTT decides taxpayer’s collagen-based products being edible and nutritious is not sufficient to make a product food for VAT zero-rating (Minerva Research Labs Ltd v HMRC)

FTT decides taxpayer’s collagen-based products being edible and nutritious is not sufficient to make a product food for VAT zero-rating (Minerva Research Labs Ltd v HMRC)

Tax analysis: In Minerva Research Labs Ltd v HMRC, the First-tier Tax Tribunal (FTT) decided that the collagen drink products concerned did not...

FTT upheld disallowance of R&D relief claims because operational innovations did not advance overall scientific or technological capability (Environmental Services v HMRC)

FTT upheld disallowance of R&D relief claims because operational innovations did not advance overall scientific or technological capability (Environmental Services v HMRC)

Tax analysis: In Environmental Services Ltd, the First-tier Tax Tribunal (FTT) dismissed the appeal of the waste handling and transporting company...

Featured Tax content

VAT treatment of damages and compensation payments

VAT treatment of damages and compensation payments

VAT treatment of damages and compensation paymentsA damages or compensation payment may attract VAT. This depends on exactly what the payment is for....

The double taxation treaty passport scheme (DTTP scheme)

The double taxation treaty passport scheme (DTTP scheme)

The double taxation treaty passport scheme (DTTP scheme)The double taxation treaty passport scheme (DTTP scheme) enables a borrower to apply for and...

What are capital allowances and capital expenditure?

What are capital allowances and capital expenditure?

What are capital allowances and capital expenditure?What are capital allowances?Capital allowances are the means by which tax relief is given for some...

If the words ‘exclusive of VAT’ are omitted from the definition of annual rent, but there is a VAT clause stating: ‘Where this lease requires the tenant to pay or provide any amount in respect of a VAT supply to the tenant...that amount will be deemed to be exclusive of VAT...and the tenant shall pay a sum equal to that VAT’, will this be sufficient to charge the tenant VAT? Is there any case law in this area?

If the words ‘exclusive of VAT’ are omitted from the definition of annual rent, but there is a VAT clause stating: ‘Where this lease requires the tenant to pay or provide any amount in respect of a VAT supply to the tenant...that amount will be deemed to be exclusive of VAT...and the tenant shall pay a sum equal to that VAT’, will this be sufficient to charge the tenant VAT? Is there any case law in this area?

If the words ‘exclusive of VAT’ are omitted from the definition of annual rent, but there is a VAT clause stating: ‘Where this lease requires the...

Practice notes

Direct tax treatment of damages and compensation payments

Direct tax treatment of damages and compensation paymentsWhere a dispute is brought to an end by a payment of damages or compensation, whether under a...
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30th May
Practice notes

Residential service charges—VAT implications

Residential service charges—VAT implicationsThis Practice Note is about the VAT treatment of residential service charges.Service charges payable to...
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Produced in partnership with Martin Scammell
13th Oct
Practice notes

Commercial service charges—VAT implications

Commercial service charges—VAT implicationsThis Practice Note is about the VAT treatment of non-residential service charges. General positionService...
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Produced in partnership with Martin Scammell
13th Oct
Practice notes

Taxation of UK LLPs

Taxation of UK LLPsA UK limited liability partnership (LLP) is a body corporate for company law purposes, but is generally taxed as though it were a...
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30th May
Practice notes

Qualifying charitable donations and excess management expenses

Qualifying charitable donations and excess management expensesAll companies within the charge to corporation tax can deduct qualifying charitable...
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30th May
Practice notes

Amortisation of intangible fixed assets

Amortisation of intangible fixed assetsWhere a company acquires (or otherwise incurs capitalised expenditure upon) an intangible fixed asset that...
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30th May
Practice notes

The Budget and Finance Bill process

The Budget and Finance Bill processThe Budget is a Parliamentary event at which the Chancellor of the Exchequer makes important announcements relating...
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30th May
Practice notes

Tax treatment of reorganisations of share capital

Tax treatment of reorganisations of share capitalThis Practice Note is about the meaning of a reorganisation for tax purposes, and the tax treatment...
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2nd Jun
Practice notes

Capital gains—intra-group asset transfers

Capital gains—intra-group asset transfersCompanies which form a group for capital gains purposes are able to transfer assets to one another free of...
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30th May
Practice notes

VAT treatment of intermediaries, agents and disbursements

VAT treatment of intermediaries, agents and disbursementsFor VAT purposes, an intermediary is a person who makes arrangements for, or facilitates, a...
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Produced in partnership with Mark Rowbotham MA FCILT of Portcullis ISC
13th Oct
Practice notes

Taxation of private equity funds—the investors

How are investors in a private equity fund taxed on their share of the profits?This Practice Note sets out how the investors in a typical UK private...
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Produced in partnership with Emily Clark of Travers Smith
13th Oct
Practice notes

Tax and offshore funds—what is an offshore fund?

Taxation of offshore funds—what is an offshore fund?Background to the offshore funds rulesSpecific tax legislation dealing with offshore funds was...
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Produced in partnership with Michael Alliston of Norton Rose Fulbright
13th Oct
Practice notes

Partnerships and capital gains

Partnerships and capital gainsThis Practice Note is about the capital gains tax and corporation tax on chargeable gains treatment of UK general...
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2nd Jun
Practice notes

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

Tax considerations on a loan agreement—the tax gross up clauseIt is standard market practice for loan agreements (also known as facility agreements),...
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Produced in partnership with Eloise Walker of Pinsent Masons
13th Oct
Q&As

For stamp duty relief under section 77 of the Finance Act 1986 (FA 1986) to apply, must the acquiring company in a share for share exchange have a share structure identical to the target company?

For stamp duty relief under section 77 of the Finance Act 1986 (FA 1986) to apply, must the acquiring company in a share for share exchange have a...
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2nd Jun
Practice notes

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)UK real estate can be held as an investment through an offshore...
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2nd Jun

Popular documents

Key CGT implications for shareholders in a rights issue

Key CGT implications for shareholders in a rights issueThis Practice Note:•explains the key CGT (used as shorthand for capital gains tax and corporation tax on chargeable gains) implications of a rights issue for shareholders who:◦are resident for tax purposes in the UK, and◦hold their existing

Priority between loss reliefs in loss making companies

Priority between loss reliefs in loss making companiesWhy does it matter?A company that is a member of a group and has incurred any of the types of losses available for surrender by way of group relief may, without any further rules, have more than one way in which to use the loss. There are a

Contributory negligence in personal injury claims

Contributory negligence in personal injury claimsContributory negligence is a partial defence which can lead to a discount in damages.Other defences may also be relevant. See Practice Notes: Did the claimant consent to the risk of injury? and Was the claimant involved in an illegal activity?If a

Glossary—Latin legal terms

Glossary—Latin legal termsDespite attempts in recent years to simplify the language used in legal cases, there are still a number of Latin phrases commonly used in personal injury claims. The following Latin phrases are listed in alphabetical order:Latin termDefinitionMeaningActa iure imperiiLegal