Cross-border transactions

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Practice notes
Share sale or asset sale—tax considerationsThe sale of a company's business can be structured as either:•a sale of assets owned by the company (an...
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19th May
Practice notes
VAT—triangulationIP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit transition/implementation period entered into following...
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Produced in partnership with John Fuszard of Sagars Accountants Ltd 19th May
Practice notes
How employment income is taxed—non-cash earnings or benefitsIn addition to cash earnings, such as wages or salaries, many reward packages include...
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19th May
Practice notes
UK Crown Dependency/Overseas Territory Agreements (CDOT)—FAQsWhat are the CDOT agreements?The UK entered into agreements with its three Crown...
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Produced in partnership with Ali Kazimi of Hansuke 19th May
Practice notes
Corporation tax—connected personsThis Practice Note looks at the meaning of connected persons within sections 1122 and 1123 of the Corporation Tax Act...
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19th May
Practice notes
Property holding structures—direct tax treatment of a Jersey property unit trust (JPUT)STOP PRESS relating to property rich collective investment...
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19th May
Practice notes
VAT on composite suppliesSingle composite supplies vs multiple suppliesWhere a supply comprises a number of different elements with varying VAT...
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Produced in partnership with Martin Shah and Gary Barnett of Simmons & Simmons LLP 19th May
Practice notes
Offshore receipts in respect of intangible property (ORIP)Since 6 April 2019, a person that is neither UK tax resident nor resident in a full treaty...
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19th May
Practice notes
FATCA in the UK—the UK:US Intergovernmental Agreement: an outlineIP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit...
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Produced in partnership with Ali Kazimi and Chris Orchard of Hansuke Consulting Limited 19th May
Practice notes
Tax considerations on a loan agreement—the tax gross up clauseIP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit...
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Produced in partnership with Eloise Walker of Pinsent Masons 19th May
Practice notes
Taxation of UK LLPsA UK limited liability partnership (LLP) is a body corporate for company law purposes, but is generally taxed as though it were a...
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19th May
Practice notes
Loan capital exemption from stamp dutyDebt which:•qualifies as loan capital (whether it is short or long-term debt), and•satisfies further conditions...
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19th May
Q&As
Corporate redomiciliation—can a non-UK company redomicile into the UK?It is possible for a non-UK incorporated company to redomicile to the UK....
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19th May
Practice notes
R&D capital allowancesFORTHCOMING CHANGE: At Spring Budget 2021, the government announced a wide-ranging review of research and development (R&D)...
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Produced in partnership with Anne Fairpo of Temple Tax Chambers 19th May
Practice notes
Transfer of a trade under common ownershipSometimes the restructuring of a business will involve a company transferring an existing trade to a...
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19th May
Practice notes
SDLT group reliefFORTHCOMING CHANGE relating to FA 2008, Sch 36: In its Tax Information and Impact Note (TIIN) on freeports, the government announced...
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19th May

Most recent Cross-border transactions content

Q&As
What tax issues should be considered when transferring a non-UK company to a UK company in a share for share exchange?Where a non-UK company is...
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1st Aug
Q&As
Is a licence of intellectual property by an Australian company to a UK private individual subject to UK VAT?In order to assess whether a cross-border...
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1st Aug
Practice notes
UK tax considerations for a UK corporate borrower borrowing from an overseas lenderIP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of...
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Produced in partnership with Ben Jones and Deepesh Upadhyay of Eversheds Sutherland LLP and Tim Shaw of Ensors Accountants LLP 31st Jul
Practice notes
Tax considerations for a UK bank lender when lending to an overseas borrowerIP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the...
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Produced in partnership with Ben Jones and Deepesh Upadhyay of Eversheds Sutherland LLP and Tim Shaw of Ensors Accountants LLP 31st Jul
Practice notes
Tax issues on financing an inbound investmentIP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit transition/implementation...
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Produced in partnership with Jacob Gilkes of CMS 31st Jul
Practice notes
Profit fragmentation and tax avoidanceFrom April 2019, the profit fragmentation rules aim to prevent UK-resident individuals, including individual...
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31st Jul
Practice notes
What are the UK tax considerations for an overseas purchaser acquiring a UK business?A non-UK based purchaser of a UK business (or UK-headquartered...
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Produced in partnership with Ben Jones of Eversheds Sutherland and Tim Shaw of Blick Rothenberg 31st Jul
Practice notes
Offshore receipts in respect of intangible property (ORIP)Since 6 April 2019, a person that is neither UK tax resident nor resident in a full treaty...
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31st Jul
Practice notes
UK tax aspects of cross-border IP structuring—exploitation of IPThis Practice Note sets out the UK perspective on various tax issues that should be...
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Produced in partnership with Anne Fairpo, barrister 31st Jul
Practice notes
UK tax aspects of cross-border IP structuring—development and acquisition of IPIn 2013 the UK government introduced its flagship patent box relief...
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Produced in partnership with Anne Fairpo, barrister 30th Jul
Practice notes
What are the UK and generic overseas tax considerations for a UK purchaser acquiring an overseas business?A UK based purchaser of an overseas business...
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Produced in partnership with Simon Letherman and Michael Ward of Shearman & Sterling (London) LLP 30th Jul
Practice notes
Cross-border private M&A transactionsThis Practice Note provides an overview of issues that are likely to be encountered by an English-qualified...
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Produced in partnership with Michael Scargill of Shearman & Sterling 30th Jul

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