Equity capital markets

View Tax by content type:

News

Practice notes

Precedents

Q&As

Latest Tax News

Supreme Court finds taxpayer had not made deliberate inaccuracy and that staleness is not relevant to discovery (HMRC v Raymond Tooth)

The following Private Client news provides comprehensive and up to date legal information on Supreme Court finds taxpayer had not made deliberate inaccuracy and that staleness is not relevant to discovery (HMRC v Raymond Tooth)

Tax weekly highlights—13 May 2021

The following Tax news provides comprehensive and up to date legal information on Tax weekly highlights—13 May 2021

Contracts—‘Reasonable detail’ in notice clause determined by business purpose (Dodika Ltd and others v United Luck Group Holdings Ltd)

The following Commercial news provides comprehensive and up to date legal information on Contracts—‘Reasonable detail’ in notice clause determined by business purpose (Dodika Ltd and others v United Luck Group Holdings Ltd)

Taxpayer’s Ramsay argument fails before the Court of Appeal (Khan v HMRC)

The following Tax news provides comprehensive and up to date legal information on Taxpayer’s Ramsay argument fails before the Court of Appeal (Khan v HMRC)

Featured Tax content

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...

Clause—tax gross up—commercial agreements

1 Withholding and grossing up 1.1 All sums payable under this [Agreement] by or on behalf of any party (for the...

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...

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...

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...

9th Nov

Practice notes

VAT treatment of damages and compensation payments

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...

9th Nov

In-house

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...

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...

Produced in partnership with Philip Rutherford 12th Jan

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...

9th Nov

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...

Produced in partnership with Ali Kazimi and Chris Orchard of Hansuke Consulting Limited 12th Jan

In-house

Practice notes

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

It is standard market practice for loan agreements (also known as facility agreements), whether bilateral or syndicated, to:•prohibit a borrower from...

Produced in partnership with Eloise Walker of Pinsent Masons 12th Jan

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...

Produced in partnership with Martin Wilson 12th Jan

Practice notes

Capital reduction demergers

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:...

Produced in partnership with Zoe Feller of Bird & Bird 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...

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...

Produced in partnership with Martin Wilson 12th Jan

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,...

9th Nov

Practice notes

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...

Produced in partnership with Charlotte Sallabank of Katten Muchin Rosenman UK LLP 12th Jan

Practice notes

VAT—triangulation

Brexit: This Practice Note contains information on subjects impacted by the UK’s withdrawal from the EU. The Taxation (Cross-border Trade) Act 2018,...

Produced in partnership with John Fuszard of Sagars Accountants Ltd 12th Jan

Practice notes

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...

9th Nov

Practice notes

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...

Produced in partnership with Anne Fairpo of Temple Tax Chambers 12th Jan

Most recent Equity capital markets content

Q&As

On a share buyback carried out by a UK company, one would usually expect any proceeds received by a UK shareholder in excess of the subscription price (broadly speaking) to be taxed as a dividend distribution. Does the same position apply to the proceeds received by a UK shareholder on a buyback carried out by an overseas company?

On a share buyback carried out by a UK company, one would usually expect any proceeds received by a UK shareholder in excess of the subscription price...

11th May

Practice notes

VCTs—circumstances in which relief is withdrawn or reduced

Like the enterprise investment scheme (EIS), the venture capital trust (VCT) regime is designed to encourage investment in smaller, higher-risk...

27th Apr

Practice notes

Key tax considerations for the issuer in a rights issue

IP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit transition/implementation period entered into following the UK’s...

9th Apr

Practice notes

EIS—circumstances in which relief is withdrawn or reduced

IP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit transition/implementation period entered into following the UK’s...

9th Apr

Practice notes

Tax incentives for companies investing in AIM companies

A few tax incentives are available to companies investing in unlisted shares and securities such as shares admitted to trading on AIM. AIM is one of...

9th Apr

Practice notes

Key CGT implications for shareholders in a rights issue

This practice note:•explains the key CGT (shorthand for capital gains tax and corporation tax on chargeable gains) implications of a rights issue for...

9th Apr

Practice notes

EIS—introduction to regime and description of tax reliefs

The EIS is designed to encourage investment in smaller, higher-risk trading companies by offering a range of tax reliefs to individual investors...

9th Apr

Sustainable Business Toolkit

Practice notes

Tax incentives for individuals investing in AIM companies

Various tax incentives are available to individuals investing in unlisted shares and securities such as shares admitted to trading on AIM. AIM is one...

9th Apr

Practice notes

Share buybacks—calculating the distribution and repayment of capital elements

From a shareholder’s perspective, when a company buys back its own shares, either directly or through an intermediary acting as agent for the company...

9th Apr

Practice notes

Tax consequences of share buybacks

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...

9th Apr

Practice notes

EIS—process for seeking advance assurance and claiming relief

The EIS is designed to encourage investment in smaller, higher-risk trading companies by offering a range of tax reliefs to individual investors...

9th Apr

Practice notes

Growth market exemption from stamp duty and SDRT

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...

9th Apr

Practice notes

What is a rights issue?

This practice note explains what a rights issue is.For more information on the corporate law aspects of rights issues, including the types of...

9th Apr

Practice notes

Stamp duty and SDRT implications of a rights issue

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...

9th Apr

Practice notes

Tax disclosure in a rights issue offer document

This practice note sets out the tax information that is required to be disclosed in a rights issue offer document (sometimes called a prospectus)...

9th Apr

Practice notes

Unquoted trading company share buybacks—capital treatment rules

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...

9th Apr

Practice notes

IHT—business property relief

Business property relief (BPR) is an important relief for inheritance tax (IHT) purposes. The relief applies both to individuals and to trusts that...

Produced in partnership with Hayden Bailey and Gabrielle Dewes of Boodle Hatfield 9th Apr

Practice notes

Individual savings accounts

Individual savings accounts (ISAs) are tax-free funds in which UK residents can hold a range of different investments. Originally, these were cash or...

Produced in partnership with Tolley Guidance 9th Apr

Practice notes

VCTs—introduction, tax reliefs and returns

Like the enterprise investment scheme (EIS), the VCT regime is designed to encourage investment in smaller, higher-risk trading companies. A VCT is a...

30th Mar

Practice notes

Stamp duty and stamp duty reserve tax implications of stabilisation transactions, including the over-allotment or greenshoe option

In the context of an offering of shares to the public by way of an initial public offering (IPO) or a secondary offering of shares, this Practice Note...

1st Mar

Equity capital markets

View Tax by content type:

Latest Tax News

Supreme Court finds taxpayer had not made deliberate inaccuracy and that staleness is not relevant to discovery (HMRC v Raymond Tooth)

Tax weekly highlights—13 May 2021

Contracts—‘Reasonable detail’ in notice clause determined by business purpose (Dodika Ltd and others v United Luck Group Holdings Ltd)

Taxpayer’s Ramsay argument fails before the Court of Appeal (Khan v HMRC)

Featured Tax content

Tax considerations on a loan agreement—the tax indemnity clause

Clause—tax gross up—commercial agreements

Property authorised investment funds (PAIFs)—summary

EIS funds, including approved knowledge-intensive funds

Most recent Equity capital markets content

Popular documents

Arbitration agreements—definition, purpose and interpretation

What is practical completion?

What is a statutory declaration of solvency, and what happens if a false declaration of solvency is made

Fiduciary Duties

Contact Us

Popular Links

Policies

Follow us