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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
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
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...
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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
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...
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Produced in partnership with Philip Rutherford 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
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
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
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 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
Brexit: As of exit day (31 January 2020) the UK is no longer an EU Member State. However, in accordance with the Withdrawal Agreement, the UK has...
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Produced in partnership with Martin Shah and Gary Barnett of Simmons & Simmons LLP 12th Jan
Practice notes
Plant and machinery allowances are the most widely used form of capital allowance. Plant and machinery is often (wrongly) interpreted as if the terms...
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Produced in partnership with Martin Wilson 12th Jan
Practice notes
Brexit: This Practice Note contains information on subjects impacted by the UK’s withdrawal from the EU. The Taxation (Cross-border Trade) Act 2018,...
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Produced in partnership with John Fuszard of Sagars Accountants Ltd 12th Jan
Practice notes
Stamp duty land tax (SDLT) ceased to apply to any land transaction involving any interests in or over land in Scotland from 1 April 2015. From that...
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9th Nov
Practice notes
FORTHCOMING CHANGE relating to property rich collective investment vehicles and certain investors: HMRC is consulting until 16 December 2020 on draft...
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9th Nov
Practice notes
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...
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Produced in partnership with Anne Fairpo of Temple Tax Chambers 12th Jan

Most recent Loans content

Practice notes
Basic principles of secondary trading and loan portfolio sales for tax lawyersSecondary debt trading is the activity of one investor purchasing debt...
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15th May
Practice notes
Tax considerations on a loan agreement—the tax gross up clauseIP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit...
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Produced in partnership with Eloise Walker of Pinsent Masons 15th May
Practice notes
UK withholding tax on yearly interestUnless an exemption or a relief applies, a payment of UK source yearly interest is subject to UK withholding tax...
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15th May
Practice notes
Exemption from UK withholding tax on interest and royalty payments made to an associated EU resident company before 1 June 2021This Practice Note is...
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15th May
Practice notes
Types of lendingOverdrafts, term loans and revolving credit facilitiesThree common types of loan facility are:•overdrafts•term loans, and•revolving...
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15th May
Practice notes
Applications for double tax treaty relief from UK withholding tax on interestFor more information on the other types of exemptions and reliefs from UK...
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15th May
Practice notes
Hybrid and other mismatchesFORTHCOMING CHANGE: In response to a consultation on changes to the hybrid mismatch rules that closed on 29 August 2020,...
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Produced in partnership with Dominic Robertson of Slaughter and May 15th May
Practice notes
Taxation of loan relationships—impairment and debt releasesIP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit...
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15th May
Practice notes
Tax issues on financing an inbound investmentIP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit transition/implementation...
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Produced in partnership with Jacob Gilkes of CMS 15th May
Practice notes
The debt cap—tested expense, available and tested income amounts [Archived]ARCHIVED: This Practice Note has been archived and is not maintained.With...
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15th May
Practice notes
Exemptions and reliefs from UK withholding tax on yearly interestUnless an exemption or relief applies, payments of:•yearly interest (or amounts that...
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15th May
Practice notes
Basic principles of syndication and transfer of loans for tax lawyersSyndicationIn a syndicated transaction, two or more lenders agree to make loans...
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15th May
Practice notes
Loan relationships—anti-avoidance: foreign exchange gains and lossesIP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit...
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15th May
Practice notes
The debt cap—disallowance of finance expenses and exemption of finance income [Archived]ARCHIVED: This Practice Note has been archived and is not...
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15th May
Practice notes
Loan relationships—anti-avoidance: related transactions not at arm's lengthIP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the...
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15th May
Practice notes
Tax considerations on a loan agreement—treaty lendersIP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit...
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15th May
Practice notes
Corporate interest restrictionFORTHCOMING CHANGE: Finance Bill 2021 contains two technical amendments to the corporate interest restriction (CIR)...
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15th May
Practice notes
The debt cap—worldwide groups, the gateway test and the financial services group exclusion [Archived]ARCHIVED: This Practice Note has been archived...
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15th May
Practice notes
The syndicated loan scheme (SLS)Unless an exemption or a relief applies, a payment of yearly interest arising in the UK (ie with a UK source) is...
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15th May
Practice notes
Loan capital exemption from stamp dutyDebt which:•qualifies as loan capital (whether it is short or long-term debt), and•satisfies further conditions...
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15th May

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