Plant and machinery allowances are the most widely used form of capital allowance. Plant and machinery is often (wrongly) interpreted as if the terms...
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...
The reasons why a company might carry out a demerger, and the different ways in which a demerger may be structured, are described in 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...
It is standard market practice for loan agreements (also known as facility agreements), whether bilateral or syndicated, to:•prohibit a borrower from...
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...
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...
The regime for property authorised investment funds (PAIFs, or as HMRC use in regulations and their published guidance, Property AIFs)) was introduced...
A management buyout, or MBO, involves the acquisition of a business by its existing management team usually with the help of private equity financing....
The international movement of capital rules should be considered whenever:•any non-UK tax resident subsidiary (referred to in this note as a foreign...
FORTHCOMING CHANGE: In response to a consultation on changes to the hybrid mismatch rules that closed on 29 August 2020, it is expected that Finance...
This Practice Note summarises the key anti-avoidance rules that may apply to restrict the tax deductibility of loan interest for a corporate borrower...
Debt which:•qualifies as loan capital (whether it is short or long-term debt), and•satisfies further conditions aimed at ensuring that it is a normal...
FORTHCOMING CHANGE: Finance Bill 2020–2021 will contain two technical amendments to the CIR rules to ensure the regime works as intended. The first is...
Overdrafts, term loans and revolving credit facilitiesThree common types of loan facility are:•overdrafts•term loans, and•revolving credit facilities...
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