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...
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:...
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...
It is standard market practice for loan agreements (also known as facility agreements), whether bilateral or syndicated, to:•prohibit a borrower from...
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 regime for property authorised investment funds (PAIFs, or as HMRC use in regulations and their published guidance, Property AIFs)) was introduced...
A management buyout, or MBO, involves the acquisition of a business by its existing management team usually with the help of private equity financing....
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...
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 share buyback is typically structured in one of three ways:•an intermediary (usually the company’s broker) acting as principal purchases the shares...
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...
A private limited company will only buy back its own shares off-market pursuant to a share buyback contract, which will include provisions specifying...
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...
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