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Latest Tax News

Supreme Court finds taxpayer had not made deliberate inaccuracy and that staleness is not relevant to discovery (HMRC v Raymond Tooth)

The following Private Client news provides comprehensive and up to date legal information on Supreme Court finds taxpayer had not made deliberate inaccuracy and that staleness is not relevant to discovery (HMRC v Raymond Tooth)

Tax weekly highlights—13 May 2021

The following Tax news provides comprehensive and up to date legal information on Tax weekly highlights—13 May 2021

Contracts—‘Reasonable detail’ in notice clause determined by business purpose (Dodika Ltd and others v United Luck Group Holdings Ltd)

The following Commercial news provides comprehensive and up to date legal information on Contracts—‘Reasonable detail’ in notice clause determined by business purpose (Dodika Ltd and others v United Luck Group Holdings Ltd)

Taxpayer’s Ramsay argument fails before the Court of Appeal (Khan v HMRC)

The following Tax news provides comprehensive and up to date legal information on Taxpayer’s Ramsay argument fails before the Court of Appeal (Khan v HMRC)

Featured Tax content

Tax considerations on a loan agreement—the tax indemnity clause

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...

International movement of capital

The international movement of capital rules should be considered whenever:•any non-UK tax resident subsidiary (referred to in this note as a foreign...

Management buyouts—summary of tax issues for management

A management buyout, or MBO, involves the acquisition of a business by its existing management team usually with the help of private equity financing....

Value shifting

The value shifting rules are anti-avoidance provisions. They are similar to the rules applying to depreciatory transactions in that they target the...

Practice notes

EIS funds, including approved knowledge-intensive funds

The Enterprise Investment Scheme (EIS) is designed to encourage investment in smaller, higher-risk trading companies by offering a range of tax...

9th Nov

Practice notes

Types of lending

Overdrafts, term loans and revolving credit facilitiesThree common types of loan facility are:•overdrafts•term loans, and•revolving credit facilities...

9th Nov

Practice notes

VAT treatment of damages and compensation payments

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...

9th Nov

In-house

Practice notes

Direct tax treatment of damages and compensation payments

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...

9th Nov

Practice notes

What is a tax determination?

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...

Produced in partnership with Philip Rutherford 12th Jan

Practice notes

Schemes of reconstruction defined

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...

9th Nov

Practice notes

FATCA in the UK—the UK:US Intergovernmental Agreement: an outline

Coronavirus (COVID-19): HMRC has stated in its International Manual that if a financial institution cannot meet the FATCA reporting deadline of 31 May...

Produced in partnership with Ali Kazimi and Chris Orchard of Hansuke Consulting Limited 12th Jan

In-house

Practice notes

Tax considerations on a loan agreement—the tax gross up clause

It is standard market practice for loan agreements (also known as facility agreements), whether bilateral or syndicated, to:•prohibit a borrower from...

Produced in partnership with Eloise Walker of Pinsent Masons 12th Jan

Practice notes

Section 198 and 199 elections on transactions involving real estate

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...

Produced in partnership with Martin Wilson 12th Jan

Practice notes

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 sale of all the shares...

9th Nov

Practice notes

VAT on composite supplies

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...

Produced in partnership with Martin Shah and Gary Barnett of Simmons & Simmons LLP 12th Jan

Practice notes

Plant and machinery allowances—definition of plant and machinery

Plant and machinery allowances are the most widely used form of capital allowance. Plant and machinery is often (wrongly) interpreted as if the terms...

Produced in partnership with Martin Wilson 12th Jan

Practice notes

VAT—triangulation

Brexit: This Practice Note contains information on subjects impacted by the UK’s withdrawal from the EU. The Taxation (Cross-border Trade) Act 2018,...

Produced in partnership with John Fuszard of Sagars Accountants Ltd 12th Jan

Practice notes

SDLT—deeds of rectification

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...

9th Nov

Practice notes

Property holding structures—direct tax treatment of a Jersey property unit trust (JPUT)

FORTHCOMING CHANGE relating to property rich collective investment vehicles and certain investors: HMRC is consulting until 16 December 2020 on draft...

9th Nov

Practice notes

What is an intangible fixed asset?

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...

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 lawyers

Basic principles of secondary trading and loan portfolio sales for tax lawyersSecondary debt trading is the activity of one investor purchasing debt...

15th May

Practice notes

Tax considerations on a loan agreement—the tax gross up clause

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...

Produced in partnership with Eloise Walker of Pinsent Masons 15th May

Practice notes

UK withholding tax on yearly interest

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...

15th May

Practice notes

Exemption from UK withholding tax on interest and royalty payments made to an associated EU resident company before 1 June 2021

Exemption from UK withholding tax on interest and royalty payments made to an associated EU resident company before 1 June 2021This Practice Note is...

15th May

Practice notes

Types of lending

Types of lendingOverdrafts, term loans and revolving credit facilitiesThree common types of loan facility are:•overdrafts•term loans, and•revolving...

15th May

Practice notes

Applications for double tax treaty relief from UK withholding tax on interest

Applications for double tax treaty relief from UK withholding tax on interestFor more information on the other types of exemptions and reliefs from UK...

15th May

Practice notes

Hybrid and other mismatches

Hybrid and other mismatchesFORTHCOMING CHANGE: In response to a consultation on changes to the hybrid mismatch rules that closed on 29 August 2020,...

Produced in partnership with Dominic Robertson of Slaughter and May 15th May

Practice notes

Taxation of loan relationships—impairment and debt releases

Taxation of loan relationships—impairment and debt releasesIP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit...

15th May

Practice notes

Tax issues on financing an inbound investment

Tax issues on financing an inbound investmentIP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit transition/implementation...

Produced in partnership with Jacob Gilkes of CMS 15th May

Practice notes

The debt cap—tested expense, available and tested income amounts [Archived]

The debt cap—tested expense, available and tested income amounts [Archived]ARCHIVED: This Practice Note has been archived and is not maintained.With...

15th May

Practice notes

Exemptions and reliefs from UK withholding tax on yearly interest

Exemptions and reliefs from UK withholding tax on yearly interestUnless an exemption or relief applies, payments of:•yearly interest (or amounts that...

15th May

Practice notes

Basic principles of syndication and transfer of loans for tax lawyers

Basic principles of syndication and transfer of loans for tax lawyersSyndicationIn a syndicated transaction, two or more lenders agree to make loans...

15th May

Practice notes

Loan relationships—anti-avoidance: foreign exchange gains and losses

Loan relationships—anti-avoidance: foreign exchange gains and lossesIP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit...

15th May

Practice notes

The debt cap—disallowance of finance expenses and exemption of finance income [Archived]

The debt cap—disallowance of finance expenses and exemption of finance income [Archived]ARCHIVED: This Practice Note has been archived and is not...

15th May

Practice notes

Loan relationships—anti-avoidance: related transactions not at arm's length

Loan relationships—anti-avoidance: related transactions not at arm's lengthIP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the...

15th May

Practice notes

Tax considerations on a loan agreement—treaty lenders

Tax considerations on a loan agreement—treaty lendersIP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit...

15th May

Practice notes

Corporate interest restriction

Corporate interest restrictionFORTHCOMING CHANGE: Finance Bill 2021 contains two technical amendments to the corporate interest restriction (CIR)...

15th May

Practice notes

The debt cap—worldwide groups, the gateway test and the financial services group exclusion [Archived]

The debt cap—worldwide groups, the gateway test and the financial services group exclusion [Archived]ARCHIVED: This Practice Note has been archived...

15th May

Practice notes

The syndicated loan scheme (SLS)

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...

15th May

Practice notes

Loan capital exemption from stamp duty

Loan capital exemption from stamp dutyDebt which:•qualifies as loan capital (whether it is short or long-term debt), and•satisfies further conditions...

15th May

Loans

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Latest Tax News

Supreme Court finds taxpayer had not made deliberate inaccuracy and that staleness is not relevant to discovery (HMRC v Raymond Tooth)

Tax weekly highlights—13 May 2021

Contracts—‘Reasonable detail’ in notice clause determined by business purpose (Dodika Ltd and others v United Luck Group Holdings Ltd)

Taxpayer’s Ramsay argument fails before the Court of Appeal (Khan v HMRC)

Featured Tax content

Tax considerations on a loan agreement—the tax indemnity clause

International movement of capital

Management buyouts—summary of tax issues for management

Value shifting

Most recent Loans content

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Conditions precedent in commercial contracts

Contract interpretation—express terms in contracts

Strike out—no reasonable grounds for bringing or defending the claim (CPR 3.4(2)(a))

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