Finance

Finance guidance:

For more information on the other types of exemptions and reliefs from UK withholding tax that are available, see Practice Note: Exemptions and reliefs from UK...

Practice Note

This Practice Note outlines what is normally covered in a UK tax opinion given by the tax lawyers acting for a UK tax resident securitisation company involved in an...

Practice Note

This Practice Note considers the UK taxation treatment of securitisation companies that fall within the scope of the permanent securitisation regime. It explains: • what...

Practice Note

Secondary debt trading is the activity of one investor purchasing debt on the secondary loan market from another investor, who may have become a lender upon origination...

Practice Note

Syndication In a syndicated transaction, two or more lenders agree to make loans to a borrower on common terms which are set out in a single facility agreement entered...

Practice Note

One of the features used to categorise loans is the number of lenders involved. A loan involving one lender is known as a 'bilateral loan'. A loan involving more than one...

Practice Note

This Practice Note examines: • the stamp taxes that arise on issue or subsequent transfer of: ◦ bearer bonds, and ◦ registered bonds • exemptions from the imposition of...

Practice Note

The requirement to deduct tax from UK source interest payments (ie withholding tax) is one of the key factors to be considered in the context of a bond issue in the UK....

Practice Note

The rules comprising the corporate interest restriction are lengthy and complex. To assist the reader, this Practice Note starts with a background section and a short,...

Practice Note

BREXIT: The UK is leaving the EU on Exit Day (as defined in the European Union (Withdrawal) Act 2018). This has an impact on this Practice Note. For guidance, see...

Practice Note

The general rule is that: • the credits (broadly, but not necessarily, profits), and • debits (broadly, but not necessarily, losses) arising to a company from its...

Practice Note

The general rule is that: • the credits (broadly, but not necessarily, profits), and • debits (broadly, but not necessarily, losses) arising to a company from its...

Practice Note

Certain securities and contracts do not naturally fall within just one of the loan relationships regime or the derivative contracts regime. In addition, some...

Practice Note

Certain securities and contracts do not naturally fall within just one of the loan relationships regime or the derivative contracts regime. In addition, some contracts...

Practice Note

The derivative contracts regime in Part 7 of the Corporation Tax Act 2009 (CTA 2009) calculates a company's taxable profits (and losses available for relief) arising from...

Practice Note

The derivative contracts rules: • form a self-contained, exclusive, regime for the taxation of a company's income, profits and gains (and relief for losses) arising from...

Practice Note