Individuals and income tax

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Practice notes
Unilateral relief, like double tax relief, aims to relieve double taxation. Subject to certain conditions being satisfied and specific limits,...
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9th Nov
Practice notes
Plant and machinery allowances are the most widely used form of capital allowance. Plant and machinery is often (wrongly) interpreted as if the terms...
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Produced in partnership with Martin Wilson 12th Jan
Practice notes
Brexit: As of exit day (31 January 2020) the UK is no longer an EU Member State. However, in accordance with the Withdrawal Agreement, the UK has...
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Produced in partnership with Martin Shah and Gary Barnett of Simmons & Simmons LLP 12th Jan
Practice notes
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...
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9th Nov
Practice notes
It is standard market practice for loan agreements (also known as facility agreements), whether bilateral or syndicated, to:•prohibit a borrower from...
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Produced in partnership with Eloise Walker of Pinsent Masons 12th Jan
Practice notes
Coronavirus (COVID-19): HMRC has stated in its International Manual that if a financial institution cannot meet the FATCA reporting deadline of 31 May...
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Produced in partnership with Ali Kazimi and Chris Orchard of Hansuke Consulting Limited 12th Jan
Practice notes
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...
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9th Nov
Practice notes
This Practice Note explains:•what a determination in respect of direct tax (ie a direct tax determination) is•when HMRC might issue a direct tax...
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Produced in partnership with Philip Rutherford 12th Jan
Practice notes
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...
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9th Nov
Practice notes
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...
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9th Nov
Practice notes
Overdrafts, term loans and revolving credit facilitiesThree common types of loan facility are:•overdrafts•term loans, and•revolving credit facilities...
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9th Nov
Practice notes
The Enterprise Investment Scheme (EIS) is designed to encourage investment in smaller, higher-risk trading companies by offering a range of tax...
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9th Nov
Practice notes
The regime for property authorised investment funds (PAIFs, or as HMRC use in regulations and their published guidance, Property AIFs)) was introduced...
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Produced in partnership with Martin Shah of Simmons & Simmons LLP based on material originally written by Charles Goddard of Rosetta Tax LLP 12th Jan
Practice notes
The value shifting rules are anti-avoidance provisions. They are similar to the rules applying to depreciatory transactions in that they target the...
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9th Nov
Practice notes
The international movement of capital rules should be considered whenever:•any non-UK tax resident subsidiary (referred to in this note as a foreign...
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9th Nov
Practice notes
This Practice Note:•explains:◦the purpose of the tax indemnity clause that is normally found in a loan agreement, and◦that the standard drafting of...
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9th Nov

Most recent Individuals and income tax content

Practice notes
This Practice Note briefly summarises the main UK taxes which may apply to non-UK resident individuals, including income tax, capital gains tax (CGT),...
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22nd Jan
Practice notes
The concepts of residence and domicile are used to establish the extent of an individual's liability to UK taxation. This Practice Note provides a...
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22nd Jan
Practice notes
STOP PRESS: On 9 April 2020, a letter from the Chancellor to the Chair of the Treasury Select Committee was published, which outlined a proposed...
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Produced in partnership with Stephen Parnham 22nd Jan
Practice notes
Transfer of Assets Abroad CodeThe anti-avoidance provisions relating to a transfer of assets abroad are contained in Chapter 2, Part 13 of the Income...
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22nd Jan
Practice notes
This Practice Note considers the charging provision under section 727 of the Income Tax Act (ITA 2007) applicable to transferors of assets abroad who...
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22nd Jan
Practice notes
The UK has a comprehensive code for the taxation of employment income. This Practice Note deals with the basic principles of income tax on employment...
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18th Jan
Practice notes
STOP PRESS: On 9 April 2020, a letter from the Chancellor to the Chair of the Treasury Select Committee was published, which outlined a proposed...
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Produced in partnership with Emma Loveday 15th Jan
Practice notes
A remittance of an individual’s income or chargeable gains will occur if Conditions A and B are met (or if one of Conditions C and D are...
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Produced in partnership with Clare Ludlam and Nick Warr of Taylor Wessing LLP 15th Jan
Practice notes
ARCHIVED: This Practice Note has been archived and is not maintained.The incidence of inheritance tax (IHT) depends on the domicile of an individual....
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15th Jan
Practice notes
Overseas Workday Relief (OWR) is a relief from UK income tax for certain non-domiciled individuals, who have elected to be taxed on the remittance...
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Produced in partnership with Lisa Spearman of Mercer & Hole 15th Jan
Practice notes
The calculation of income tax liabilities is usually done by a person's tax adviser or by HMRC following submission of a tax return, rather than by a...
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15th Jan
Practice notes
From April 2019, the profit fragmentation rules aim to prevent UK-resident individuals, including individual members of a partnership, and UK-resident...
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15th Jan
Practice notes
The concepts of domicile and residence are used to establish the extent of an individual’s liability to UK taxation. Specifically, domicile determines...
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15th Jan
Practice notes
This Practice Note considers the charging provisions on individuals under section 731 of the Income Tax Act 2007 (ITA 2007), also known as ‘the...
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15th Jan
Practice notes
Reliefs entitle taxpayers to reduce the amount of income tax payable. When calculating liability to income tax, a taxpayer may deduct reliefs from...
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15th Jan
Practice notes
The types of income chargeable to tax as 'savings and investment income' include:•interest, being income chargeable under ITTOIA 2005, ss...
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15th Jan
Practice notes
For income tax rates and allowances applicable in the current tax year, see Practice Note: Key UK tax rates, thresholds and allowances for Private...
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15th Jan
Practice notes
At Summer Budget 2015, the government announced wide-ranging reforms to the deemed domicile rules and also to the excluded property rules as they...
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15th Jan
Practice notes
To determine whether a remittance has occurred for the purposes of the remittance basis of taxation, reference must be made to the Conditions set out...
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Produced in partnership with Clare Ludlam and Nick Warr of Taylor Wessing LLP 15th Jan
Practice notes
To determine whether a remittance has occurred for the purposes of the remittance basis of taxation, reference must be made to the Conditions set out...
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Produced in partnership with Clare Ludlam and Nick Warr of Taylor Wessing LLP 15th Jan

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