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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 9th Nov
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 Gary Barnett, Martin Shah and Simmons & Simmons 9th Nov
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 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 9th Nov
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 9th Nov
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
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 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
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 International content

Practice notes
Brexit: This Practice Note contains information on subjects impacted by the UK’s withdrawal from the EU. The Taxation (Cross-border Trade) Act 2018,...
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Produced in partnership with John Fuszard of Sagars Accountants Ltd 1st Dec
Practice notes
This Practice Note deals with the controlled foreign company (CFC) rules that apply for accounting periods of CFCs commencing on or after 1 January...
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30th Nov
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 30th Nov
Practice notes
Updated in July 2020IntroductionCyprus is strategically located in the Eastern Mediterranean at the crossroads of Europe, Asia and Africa. It is an...
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Produced in partnership with Elena Christodoulou, Andrea Kallis Parparinou and Elias Neocleous of Elias Neocleous & Co LLC 30th Nov
Practice notes
The UK’s disclosable arrangements rules implement EU Directive 2018/822, also known as DAC 6, or the EU Mandatory Disclosure Regime (EU MDR). The...
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30th Nov
Practice notes
ARCHIVED: This Practice Note has been archived and is not maintained.On 6 October 2011, the governments of Switzerland and the UK signed an agreement...
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29th Nov
Practice notes
This Practice Note provides an introduction to the Organisation for Economic Co-operation and Development (OECD)’s Multilateral Convention on Mutual...
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29th Nov
Practice notes
Since 2007, HMRC has offered a series of disclosure facilities to individuals with offshore investments. These facilities provide a limited...
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29th Nov
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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29th Nov
Practice notes
What is the requirement to correct?The legislation for the requirement to correct (RTC) regime is set out in section 67 and Schedule 18 to the Finance...
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29th Nov
Practice notes
ARCHIVED: This Practice Note has been archived and is not maintained.The Liechtenstein Disclosure Facility (LDF) was a voluntary disclosure facility...
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29th Nov
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 29th Nov
Practice notes
This Practice Note provides a brief introduction to Tax Information Exchange Agreements (TIEAs).For guidance on the OECD's Multilateral Convention on...
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29th Nov
Practice notes
This Practice Note considers the application of the Foreign Account Tax Compliance Act (FATCA) to UK Trusts, as implemented in the UK by the...
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Produced in partnership with Jason Collins and Catherine Robins of Pinsent Masons 29th Nov
Practice notes
The UK’s first formal tax residency test for individuals known as the statutory residence test (SRT) took effect on 6 April 2013. Before this, whether...
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Produced in partnership with Lisa Spearman of Mercer and Hole and Emma Loveday of Wedlake Bell LLP 29th Nov
Practice notes
The exchange of information between HMRC and tax authorities in other territories is an essential tool in enabling authorities both to administer and...
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29th Nov
Practice notes
ARCHIVED: This Practice Note has been archived and is not maintained.In October 2013, the Isle of Man, Jersey and Guernsey each signed...
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29th Nov
Practice notes
This Practice Note deals with the new controlled foreign companies (CFC) rules that apply for accounting periods of CFCs commencing on or after 1...
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29th Nov
Practice notes
This Practice Note considers the UK tax aspects of the application of the UK’s transfer pricing rules to joint ventures, including in particular, when...
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Produced in partnership with Simon Gough and Caroline Brown of Bird & Bird LLP 29th Nov

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