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Practice notes
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...
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Produced in partnership with Charlotte Sallabank of Katten Muchin Rosenman UK LLP 12th Jan
Practice notes
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 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
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
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
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
Practice notes
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
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
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
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...
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9th Nov
Practice notes
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
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
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
Precedents
1 Withholding and grossing up 1.1 All sums payable under this [Agreement] by or on behalf of any party (for the...
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9th Nov
Practice notes
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
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 Equity capital markets content

Practice notes
Business property relief (BPR) is an important relief for inheritance tax (IHT) purposes. The relief applies both to individuals and to trusts that...
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Produced in partnership with Hayden Bailey and Gabrielle Dewes of Boodle Hatfield 15th Jan
Practice notes
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...
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15th Jan
Practice notes
This practice note:•explains the key CGT (shorthand for capital gains tax and corporation tax on chargeable gains) implications of a rights issue for...
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15th Jan
Practice notes
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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15th Jan
Practice notes
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...
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15th Jan
Practice notes
Various tax incentives are available to individuals investing in unlisted shares and securities such as shares admitted to trading on AIM. AIM is one...
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15th Jan
Practice notes
This practice note explains what a rights issue is.For more information on the corporate law aspects of rights issues, including the types of...
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15th Jan
Practice notes
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...
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15th Jan
Practice notes
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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15th Jan
Practice notes
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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15th Jan
Practice notes
STOP PRESS relating to market value consideration for transfers of listed securities to connected companies: Finance Act 2019 introduced a targeted...
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15th Jan
Practice notes
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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15th Jan
Practice notes
The EIS is designed to encourage investment in smaller, higher-risk trading companies by offering a range of tax reliefs to individual investors...
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15th Jan
Practice notes
This practice note sets out the tax information that is required to be disclosed in a rights issue offer document (sometimes called a prospectus)...
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15th Jan
Q&As
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...
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Produced in partnership with Mary Ashley of Old Square Tax Chambers 8th Jan
Practice notes
Individual savings accounts (ISAs) are tax-free funds in which UK residents can hold a range of different investments. Originally, these were cash or...
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Produced in partnership with Tolley Guidance 8th Jan
Practice notes
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...
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15th Dec
Q&As
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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6th Dec
Practice notes
The EIS is designed to encourage investment in smaller, higher-risk trading companies by offering a range of tax reliefs to individual investors...
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29th Nov

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