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...
Coronavirus (COVID-19): HMRC has stated in its International Manual that if a financial institution cannot meet the FATCA reporting deadline of 31 May...
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...
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...
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...
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...
Private equity backed companiesThe issues facing private equity backed companies when using shares to incentivise employees are similar to those faced...
The income-based carried interest (IBCI) rules form part of the legislation which governs the tax treatment of rewards received by fund managers. The...
This Practice Note looks at VAT issues arising in the context of private equity funds. It considers the VAT implications of dealings between a limited...
This Q&A assumes that the client is not treated as an employee for UK tax purposes. It also assumes that the client is a UK-resident and UK-domiciled...
When considering offering shares to employees, whether directly and/or pursuant to a share plan, employer companies and company shareholders need to...
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