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Practice notes
How employment income is taxed—non-cash earnings or benefitsIn addition to cash earnings, such as wages or salaries, many reward packages include...
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19th May
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...
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Produced in partnership with Anne Fairpo of Temple Tax Chambers 19th May
Practice notes
Key tax consequences of an insolvent liquidationThis Practice Note outlines:•the main corporation tax consequences when a UK incorporated company...
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Produced in partnership with Julia Fox of Deloitte LLP and Anthony Davis 19th May
Practice notes
Property holding structures—SDLT and VAT treatment of a Jersey Property Unit Trust (JPUT)IP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the...
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19th May
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
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
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
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
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
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

Most recent Loans content

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 Jun
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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5th Jun
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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5th Jun
Practice notes
Tax considerations on a loan agreement—the tax credit clauseIP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit...
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5th Jun
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 5th Jun
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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5th Jun
Practice notes
Tax considerations on a loan agreement—the tax indemnity clauseIP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit...
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5th Jun
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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5th Jun
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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5th Jun
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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5th Jun
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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5th Jun
Practice notes
Use of derivatives to hedge against risk in a lending contextCoronavirus (COVID-19): This Practice Note contains information on subjects potentially...
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4th Jun
Practice notes
Bilateral, syndicated and club arrangementsOne of the features used to categorise loans is the number of lenders involved. A loan involving one lender...
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4th Jun

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