Commercial service charges—VAT implicationsThis Practice Note is about the VAT treatment of non-residential service charges. General positionService...
Offshore receipts in respect of intangible property (ORIP)Since 6 April 2019, a person that is neither UK tax resident nor resident in a full treaty...
Taxation of UK LLPsA UK limited liability partnership (LLP) is a body corporate for company law purposes, but is generally taxed as though it were a...
Loan capital exemption from stamp dutyDebt which:•qualifies as loan capital (whether it is short or long-term debt), and•satisfies further conditions...
The Budget and Finance Bill processThe Budget is a Parliamentary event at which the Chancellor of the Exchequer makes important announcements relating...
Why have a tax covenant?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...
SDLT group reliefFORTHCOMING CHANGE relating to FA 2008, Sch 36: In its Tax Information and Impact Note (TIIN) on freeports, the government announced...
Debt capital market finance versus loan financeMethods of raising financeWhen a corporate entity needs to raise finance, its first choice is whether...
Loan capital exemption from stamp dutyDebt which:•qualifies as loan capital (whether it is short or long-term debt), and•satisfies further conditions...
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...
Loan relationships—anti-avoidance: unallowable purposesThe rule is that the credits (broadly, but not necessarily, profits) and debits (broadly, but...
Tax considerations on a loan agreement—the tax gross up clauseIt is standard market practice for loan agreements (also known as facility agreements),...
Basic principles of syndication and transfer of loans for tax lawyersSyndicationIn a syndicated transaction, two or more lenders agree to make loans...
The debt cap—tested expense, available and tested income amounts [Archived]ARCHIVED: This Practice Note has been archived and is not maintained.With...
Basic principles of secondary trading and loan portfolio sales for tax lawyersSecondary debt trading is the activity of one investor purchasing debt...
Applications for double tax treaty relief from UK withholding tax on interestFor more information on the other types of exemptions and reliefs from UK...
UK tax considerations for a UK corporate borrower borrowing from an overseas lenderIP COMPLETION DAY: The Brexit transition period ended at 11pm on 31...
Tax issues on financing an inbound investmentIP COMPLETION DAY: The Brexit transition period ended at 11pm on 31 December 2020. At this time (referred...
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