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Practice notes
VAT on composite suppliesSingle composite supplies vs multiple suppliesWhere a supply comprises a number of different elements with varying VAT...
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Produced in partnership with Martin Shah and Gary Barnett of Simmons & Simmons LLP 19th May
Practice notes
Commercial service charges—VAT implicationsThis Practice Note is about the VAT treatment of non-residential service charges. General positionService...
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Produced in partnership with Martin Scammell 19th May
Practice notes
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...
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19th May
Practice notes
FATCA in the UK—the UK:US Intergovernmental Agreement: an outlineIP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit...
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Produced in partnership with Ali Kazimi and Chris Orchard of Hansuke Consulting Limited 19th 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 19th May
Precedents
1 Withholding and grossing up 1.1 All sums payable under this [Agreement] by or on behalf of any party (for the...
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19th May
Practice notes
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...
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19th May
Practice notes
Section 198 and 199 elections on transactions involving real estateThis Practice Note describes the law and practice relating to elections under...
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Produced in partnership with Martin Wilson 19th 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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19th May
Practice notes
The Budget and Finance Bill processThe Budget is a Parliamentary event at which the Chancellor of the Exchequer makes important announcements relating...
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19th May
Practice notes
Capital reduction demergersThe reasons why a company might carry out a demerger, and the different ways in which a demerger may be structured, are...
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Produced in partnership with Zoe Feller of Bird & Bird 19th May
Q&As
Corporate redomiciliation—can a non-UK company redomicile into the UK?It is possible for a non-UK incorporated company to redomicile to the UK....
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19th May
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...
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19th May
Practice notes
R&D capital allowancesFORTHCOMING CHANGE: At Spring Budget 2021, the government announced a wide-ranging review of research and development (R&D)...
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Produced in partnership with Anne Fairpo of Temple Tax Chambers 19th May
Practice notes
Transfer of a trade under common ownershipSometimes the restructuring of a business will involve a company transferring an existing trade to a...
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19th May
Practice notes
SDLT group reliefFORTHCOMING CHANGE relating to FA 2008, Sch 36: In its Tax Information and Impact Note (TIIN) on freeports, the government announced...
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19th May

Most recent Loans content

Practice notes
Debt capital market finance versus loan financeMethods of raising financeWhen a corporate entity needs to raise finance, its first choice is whether...
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7th Sep
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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5th Sep
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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22nd Aug
Q&As
Where a discount on a bond is treated as disguised interest, does the deeming provision mean that income tax must be withheld at source from the...
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16th Aug
Q&As
Can a double tax treaty relief claim be made for withholding tax paid to HMRC in the form of a funding bond?Unless an exemption or relief applies,...
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16th Aug
Practice notes
Loan relationships—anti-avoidance: unallowable purposesThe rule is that the credits (broadly, but not necessarily, profits) and debits (broadly, but...
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15th Aug
Practice notes
Exemption from UK withholding tax on interest and royalty payments made to an associated EU resident company before 1 June 2021 [Archived]ARCHIVED:...
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15th Aug
Practice notes
Tax considerations on a loan agreement—the tax gross up clauseIt is standard market practice for loan agreements (also known as facility agreements),...
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Produced in partnership with Eloise Walker of Pinsent Masons 15th Aug
Practice notes
Loan relationships—anti-avoidance: related transactions not at arm's lengthIP COMPLETION DAY: The Brexit transition period ended at 11pm on 31...
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15th Aug
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 Aug
Practice notes
Corporate interest restrictionThe rules comprising the corporate interest restriction are lengthy and complex. To assist the reader, this Practice...
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15th Aug
Practice notes
Hybrid and other mismatchesThis Practice Note outlines the UK rules (referred to in this Practice Note as the hybrid rules) that counteract, for...
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Produced in partnership with Dominic Robertson of Slaughter and May 15th Aug
Practice notes
Key restrictions on tax deductibility of loan interestThis Practice Note summarises the key anti-avoidance rules that may apply to restrict the tax...
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15th Aug
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 Aug
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 Aug
Practice notes
The double taxation treaty passport scheme (DTTP scheme)The double taxation treaty passport scheme (DTTP scheme) enables a borrower to apply for and...
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15th Aug
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 Aug
Practice notes
UK tax considerations for a UK corporate borrower borrowing from an overseas lenderIP COMPLETION DAY: The Brexit transition period ended at 11pm on 31...
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Produced in partnership with Ben Jones and Deepesh Upadhyay of Eversheds Sutherland LLP and Tim Shaw of Ensors Accountants LLP 15th Aug
Practice notes
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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Produced in partnership with Jacob Gilkes of CMS 15th Aug

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