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Practice notes
FORTHCOMING CHANGE: HMRC is consulting (13 July to 10 August 2020) on draft regulations to provide a deduction from a UK entity’s equity and...
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Produced in partnership with Charlotte Sallabank of Katten Muchin Rosenman UK LLP 12th Jan
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
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
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
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 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
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 Doing business in key global jurisdictions content

Practice notes
Updated in April 2019IntroductionThe business environmentForming a companyFinancing a companyOpening a bank accountUtilising office spaceImmigration...
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Produced in partnership with Haibin Xue of Zhong Lun Law Firm 21st Jan
Practice notes
Updated in November 2019IntroductionFrance is an open market economy and provides a business-friendly environment with strong public facilities and a...
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Produced in partnership with Bersay 21st Jan
Practice notes
Updated in September 2020.•Introduction•The business environment•Forming a company•Financing a company•Opening a bank account•Utilising office...
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Produced in partnership with Andrew Lumsden of Corrs Chambers Westgarth 21st Jan
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 Elias Neocleous of Elias Neocleous & Co LLC, Andrea Kallis Parparinou of Elias Neocleous & Co LLC and Elena Christodoulou of Elias Neocleous & Co LLC 21st Jan
Practice notes
This page collects together Commercial content that addresses matters of EU law.For information on EU law generally, see EU structure, EU legislative...
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18th Jan
Practice notes
Updated in September 2020IntroductionThe Business EnvironmentForming a companyOne-Person CorporationFinancing and capital raisingOpening a bank...
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Produced in partnership with Ocampo & Suralvo Law Offices 15th Jan
Practice notes
Updated in May 2019IntroductionThe business environmentForming a companyFinancing a companyOpening a branch office and representative officeOpening a...
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Produced in partnership with Assegaf Hamzah & Partners 13th Jan
Practice notes
Updated in September 2019IntroductionChile, although distant from most countries in the world is one of South America’s most stable and prosperous...
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Produced in partnership with Luis Felipe Arze of CMS 13th Jan

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