Cross-border transactions

View Tax by content type:

Latest Tax News

Featured Tax content

Practice notes
Unilateral relief, like double tax relief, aims to relieve double taxation. Subject to certain conditions being satisfied and specific limits,...
Read More >
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...
Read More >
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...
Read More >
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...
Read More >
9th Nov
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...
Read More >
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...
Read More >
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...
Read More >
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...
Read More >
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...
Read More >
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...
Read More >
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...
Read More >
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...
Read More >
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...
Read More >
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...
Read More >
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...
Read More >
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...
Read More >
9th Nov

Most recent Cross-border transactions content

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...
Read More >
Produced in partnership with Ben Jones and Deepesh Upadhyay of Eversheds Sutherland LLP and Tim Shaw of Ensors Accountants LLP 9th Apr
Practice notes
In 2013 the UK government introduced its flagship patent box relief from corporation tax as part of the UK's wider bid to be one of the world's most...
Read More >
Produced in partnership with Anne Fairpo of Temple Tax Chambers 9th Apr
Practice notes
Since 6 April 2019, a person that is neither UK tax resident nor resident in a full treaty territory (ie not resident in a territory with which the UK...
Read More >
9th 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...
Read More >
Produced in partnership with Ben Jones and Deepesh Upadhyay of Eversheds Sutherland LLP and Tim Shaw of Ensors Accountants LLP 9th Apr
Practice notes
From April 2019, the profit fragmentation rules aim to prevent UK-resident individuals, including individual members of a partnership, and UK-resident...
Read More >
9th Apr
Practice notes
This Practice Note provides an overview of issues that are likely to be encountered by an English-qualified lawyer when advising a seller or a buyer...
Read More >
Produced in partnership with Michael Scargill of Shearman & Sterling 8th Apr
Practice notes
A non-UK based purchaser of a UK business (or UK-headquartered business) will need to consider the following tax issues:•the UK costs associated with...
Read More >
Produced in partnership with Ben Jones of Eversheds LLP and Tim Shaw of Blick Rothenberg Limited 4th Apr
Practice notes
A UK based purchaser of an overseas business will need to consider the following tax issues:•the potential overseas and UK tax costs associated with...
Read More >
Produced in partnership with Simon Letherman and Michael Ward of Shearman & Sterling (London) LLP 4th 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...
Read More >
Produced in partnership with Anne Fairpo of Temple Tax Chambers 19th Mar
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...
Read More >
Produced in partnership with Jacob Gilkes of CMS 9th Mar
Q&As
In order to assess whether a cross-border supply is subject to UK value added tax (VAT), it is necessary to consider the place of supply rules, which...
Read More >
27th Dec
Q&As
Where a non-UK company is transferred to a UK incorporated and tax-resident company by way of a share for share exchange, there are numerous potential...
Read More >
26th Nov

Popular documents