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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
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
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:...
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Produced in partnership with Zoe Feller of Bird & Bird 12th Jan
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...
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Produced in partnership with Martin Wilson 12th Jan
Practice notes
It is standard market practice for loan agreements (also known as facility agreements), whether bilateral or syndicated, to:•prohibit a borrower from...
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Produced in partnership with Eloise Walker of Pinsent Masons 12th Jan
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
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
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 regime for property authorised investment funds (PAIFs, or as HMRC use in regulations and their published guidance, Property AIFs)) was introduced...
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Produced in partnership with Martin Shah of Simmons & Simmons LLP based on material originally written by Charles Goddard of Rosetta Tax LLP 12th Jan
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
A management buyout, or MBO, involves the acquisition of a business by its existing management team usually with the help of private equity financing....
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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 Finance content

Practice notes
This Practice Note is only relevant to UK source payments of interest and/or royalties made before 1 June 2021 or, in certain circumstances, before 3...
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12th Apr
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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9th Apr
Practice notes
Debt which:•qualifies as loan capital (whether it is short or long-term debt), and•satisfies further conditions aimed at ensuring that it is a normal...
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9th Apr
Practice notes
ARCHIVED: This Practice Note has been archived and is not maintained.With effect from 1 April 2017, the worldwide debt cap rules have been repealed...
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9th Apr
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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9th Apr
Practice notes
Overdrafts, term loans and revolving credit facilitiesThree common types of loan facility are:•overdrafts•term loans, and•revolving credit facilities...
Read More >
9th Apr
Practice notes
Sukuk (singular form: ‘sakk’) is a type of Shari’a financing arrangement also referred to as Islamic bonds or certificates. For more information, see...
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Produced in partnership with Sarah Squires of Old Square Tax Chambers 9th Apr
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...
Read More >
9th Apr
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...
Read More >
9th Apr
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...
Read More >
9th Apr
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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9th Apr
Practice notes
A musharaka is a form of Islamic financing that operates as a form of shared ownership arrangement. It can be used as a Shari’a-compliant alternative...
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Produced in partnership with Sarah Squires of Old Square Tax Chambers 9th Apr
Practice notes
The double taxation treaty passport scheme (DTTP scheme) enables a borrower to apply for and obtain an expedited authorisation to pay UK source...
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9th Apr
Practice notes
Sukuk (singular form: 'sakk') is a type of Shari’a financing arrangement also referred to as Islamic bonds or certificates. For more information, see...
Read More >
Produced in partnership with Sarah Squires of Old Square Tax Chambers 9th Apr
Practice notes
This Practice Note summarises the key anti-avoidance rules that may apply to restrict the tax deductibility of loan interest for a corporate borrower...
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9th Apr
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...
Read More >
9th Apr
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...
Read More >
9th Apr
Practice notes
Shari’a compliant financing arrangements (also known as Islamic financing arrangements) can take a number of forms. The UK has introduced specific...
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Produced in partnership with Sarah Squires of Old Square Tax Chambers 9th Apr
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...
Read More >
9th Apr
Practice notes
Sukuk (singular form: ‘sakk’) is a type of Shari’a financing arrangement also referred to as Islamic bonds or certificates. For more information, see...
Read More >
Produced in partnership with Sarah Squires of Old Square Tax Chambers 9th Apr

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