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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
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:...
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Produced in partnership with Zoe Feller of Bird & Bird 12th Jan
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...
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Produced in partnership with Martin Wilson 12th Jan
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
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
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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9th Nov
Practice notes
A management buyout, or MBO, involves the acquisition of a business by its existing management team usually with the help of private equity financing....
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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 International content

Practice notes
Many UK companies operate entirely within the boundaries of the UK, with all of their customers and suppliers being based in the UK, such that all of...
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Produced in partnership with Robert O’Hare of Squire Patton Boggs 16th Apr
Practice notes
As explained in Practice Note: Foreign branch exemption—foreign permanent establishments amount there are a number of rules that must be followed in...
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Produced in partnership with Robert O’Hare of Squire Patton Boggs 16th Apr
Practice notes
This Practice Note only describes the foreign branch exemption anti-diversion rules that apply to accounting periods commencing on or after 1 January...
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Produced in partnership with Robert O’Hare of Squire Patton Boggs 16th Apr
Practice notes
This Practice Note only describes the foreign branch exemption anti-diversion rules that apply to accounting periods commencing on or after 1 January...
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Produced in partnership with Robert O’Hare of Squire Patton Boggs 16th Apr
Practice notes
This note only deals with the foreign branch exemption anti-diversion rules that apply to accounting periods commencing on or after 1 January 2013.For...
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Produced in partnership with Robert O’Hare of Squire Patton Boggs 16th Apr
Practice notes
Purpose of the regimeThe purpose of the foreign branch exemption is to exempt from UK corporation tax the profits of the worldwide permanent...
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Produced in partnership with Robert O’Hare of Squire Patton Boggs 16th Apr
Practice notes
As explained in Practice Note: Foreign branch exemption—structure of the foreign branch exemption, the concept of the foreign permanent establishments...
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Produced in partnership with Robert O’Hare of Squire Patton Boggs 16th Apr
Practice notes
Why are special rules required to deal with historic losses?As further explained in Practice Note: UK taxation of foreign profits in a UK resident...
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Produced in partnership with Robert O’Hare of Squire Patton Boggs 16th Apr
Practice notes
Updated in March 2021IntroductionThe business environmentForming a companyBeneficial ownershipFinancing a companyOpening a branch officeOpening a bank...
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Produced in partnership with Jonathan Edgelow of Vedder Price 16th Apr
Practice notes
This Practice Note is only relevant to UK source payments of interest and/or royalties made before 1 June 2021 or, in certain circumstances, before 3...
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15th Apr
Practice notes
IP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit transition/implementation period entered into following the UK’s...
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Produced in partnership with Jacob Gilkes of CMS 15th Apr
Practice notes
This Practice Note sets out the UK perspective on various tax issues that should be taken into account in deciding how an innovative IP business with...
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Produced in partnership with Anne Fairpo of Temple Tax Chambers 15th Apr
Practice notes
IP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit transition/implementation period entered into following the UK’s...
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Produced in partnership with Andrew Howard of Ropes & Gray 15th Apr
Practice notes
IP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit transition/implementation period entered into following the UK’s...
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Produced in partnership with David Klass of Hunton Andrews Kurth 15th Apr
Practice notes
A non-UK resident company doing business in the UK has a choice as to whether to form a subsidiary company in the UK, or to operate through a...
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15th Apr
Practice notes
This Practice Note is about the extent to which EU law continues to apply to the UK’s tax rules (direct tax and VAT) following the end of the Brexit...
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15th Apr
Practice notes
IP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit transition/implementation period entered into following the UK’s...
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Produced in partnership with David Klass of Hunton Andrews Kurth 15th Apr
Practice notes
This Practice Note is about the application of the EU principle of abuse of rights (or abuse of law) in the field of VAT. This is often referred to as...
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Produced in partnership with Martin Shah and Gary Barnett of Simmons & Simmons LLP 13th Apr
Practice notes
FORTHCOMING CHANGE: As described in this Practice Note, the scope of the UK’s disclosable arrangements rules was significantly reduced with effect...
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12th Apr
Practice notes
IP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit transition/implementation period entered into following the UK’s...
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Produced in partnership with Etienne Wong of Old Square Tax Chambers 12th Apr

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