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: As of 31 January 2020, the UK is no longer an EU Member State, but has entered an implementation period during which it continues to be treated by the EU as a...

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 contracts...

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

FORTHCOMING CHANGE relating to transfers within an EU group: Finance Bill 2019–20 will contain provisions permitting companies to pay tax in instalments in relation to...

Practice Note

The general position is, broadly, that the derivative contracts regime taxes (ie brings into account for corporation tax purposes) the: • credits—broadly, the receipts...

Practice Note

This Practice Note sets out rules that apply to periods of account beginning before 1 January 2015. In such periods, where certain conditions were met, the Disregard...

Practice Note

This Practice Note sets out rules that apply to periods of account beginning before 1 January 2015. In such periods, where certain conditions were met, the Disregard...

Practice Note

Hedging is the mechanism by which a company will mitigate certain risks and exposures which, broadly, have the potential to impact either: • the company's cash flow, or •...

Practice Note

Hedging is a mechanism used by companies to mitigate certain risks and exposures which, broadly, have the potential to impact either: • the company's cash flow, or • the...

Practice Note

A company will most commonly enter a hedge arrangement to mitigate risks and exposures which, broadly, have the potential to impact either: • the company's cash flow, or...

Practice Note

A company will most commonly enter a hedge arrangement to mitigate risks and exposures which, broadly, have the potential to impact either: • the company's cash flow, or...

Practice Note

The profits and losses arising to a company from its derivative contracts are, like its profits and losses from its loan relationships, generally brought into account for...

Practice Note

The profits and losses arising to a company from its derivative contracts are, like its profits and losses from its loan relationships, generally brought into account for...

Practice Note