Securitisations

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Practice notes
Direct tax treatment of damages and compensation paymentsWhere a dispute is brought to an end by a payment of damages or compensation, whether under a...
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19th May
Practice notes
SDLT—deeds of rectificationStamp duty land tax (SDLT) ceased to apply to any land transaction involving any interests in or over land in Scotland from...
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19th May
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
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
Amortisation of intangible fixed assetsWhere a company acquires (or otherwise incurs capitalised expenditure upon) an intangible fixed asset that...
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Produced in partnership with Anne Fairpo of Temple Tax Chambers 19th May
Practice notes
Corporation tax—connected personsThis Practice Note looks at the meaning of connected persons within sections 1122 and 1123 of the Corporation Tax Act...
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19th May
Practice notes
Property holding structures—direct tax treatment of a Jersey property unit trust (JPUT)STOP PRESS relating to property rich collective investment...
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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
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
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
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

Most recent Securitisations content

Q&As
What is a ‘financial asset’ under the Taxation of Securitisation Companies Regulations 2006 (SI 2006/3296)?‘Financial asset’ is defined in regulation...
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6th Jun
Practice notes
Asset-backed securitisations—the UK tax opinionThis Practice Note outlines what is normally covered in a UK tax opinion given by the tax lawyers...
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5th Jun
Practice notes
Whole business securitisations—the UK tax opinionThis Practice Note outlines what is normally covered in a UK tax opinion given by the tax lawyers...
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5th Jun
Practice notes
Securitisations and tax—companies other than the note-issuing companyThis Practice Note explains the conditions that must be satisfied for companies,...
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5th Jun
Practice notes
Asset-backed securitisations—the UK tax treatmentFORTHCOMING CHANGE: A consultation explores the potential for reforming the taxation of securitsation...
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5th Jun
Practice notes
Whole business securitisations—UK tax considerationsThis Practice Note:•explains what a whole business securitisation is—a whole business...
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5th Jun
Practice notes
Securitisations and tax—what is a note-issuing company?A note-issuing company is the most commonly encountered type of securitisation company.This...
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5th Jun
Practice notes
What is securitisation?Securitisation is a financing techniqueSecuritisation is a technique used to finance the ownership or sale of types of assets...
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4th Jun

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