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Latest Tax News

Supreme Court rules in Franked Investment Income litigation (Test Claimants in the FII Group Litigation v HMRC)

Supreme Court rules in Franked Investment Income litigation (Test Claimants in the FII Group Litigation v HMRC)

The following Tax news provides comprehensive and up to date legal information on Supreme Court rules in Franked Investment Income litigation (Test Claimants in the FII Group Litigation v HMRC)

SDLT—no MDR for land with planning permission (Ladson Preston and AKA Developments v HMRC)

SDLT—no MDR for land with planning permission (Ladson Preston and AKA Developments v HMRC)

The following Private Client news provides comprehensive and up to date legal information on SDLT—no MDR for land with planning permission (Ladson Preston and AKA Developments v HMRC)

Tax weekly highlights—22 July 2021

Tax weekly highlights—22 July 2021

The following Tax news provides comprehensive and up to date legal information on Tax weekly highlights—22 July 2021

Bonus payments received by LLP members were earnings from previous employment (Charles Tyrwhitt LLP v HMRC)

Bonus payments received by LLP members were earnings from previous employment (Charles Tyrwhitt LLP v HMRC)

The following Tax news provides comprehensive and up to date legal information on Bonus payments received by LLP members were earnings from previous employment (Charles Tyrwhitt LLP v HMRC)

Featured Tax content

Taxation of redundancy payments

Taxation of redundancy payments

Taxation of redundancy paymentsRedundancy is one of five ways in which an employment contract may be terminated unilaterally by an employer where such...

VAT treatment of parking facilities

VAT treatment of parking facilities

VAT treatment of parking facilitiesThis Practice Note is about the VAT treatment of parking facilities.Why does this matter?Charges for parking are...

Enhanced capital allowances

Enhanced capital allowances

Enhanced capital allowancesWhat is an enhanced capital allowance?An enhanced capital allowance (ECA) is a tax relief for businesses on their...

Two employees have been issued shares and entered into a section 431 election respectively. The date of the signatures is the date the shares are shown at Companies House as being issued. However, where the form requires the date the shares were acquired by the employee, a date has not been inserted. Does this invalidate the section 431 election?

Two employees have been issued shares and entered into a section 431 election respectively. The date of the signatures is the date the shares are shown at Companies House as being issued. However, where the form requires the date the shares were acquired by the employee, a date has not been inserted. Does this invalidate the section 431 election?

Two employees have been issued shares and entered into a section 431 election respectively. The date of the signatures is the date the shares are...

Practice notes

VAT—what is a transfer of a business as a going concern?

VAT—what is a transfer of a business as a going concern?IP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit...
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Produced in partnership with Cathya Djanogly 19th May
Practice notes

Property authorised investment funds (PAIFs)—summary

Property authorised investment funds (PAIFs)—summaryThe regime for property authorised investment funds (PAIFs) was introduced in 2008.It created a...
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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 19th May
Practice notes

Direct tax treatment of damages and compensation payments

Direct tax treatment of damages and compensation paymentsWhere a dispute is brought to an end by a payment of damages or compensation, whether under a...
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19th May
Practice notes

Share sale or asset sale—tax considerations

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

How employment income is taxed—non-cash earnings or benefits

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

What is an intangible fixed asset?

What is an intangible fixed asset?Part 8 of the Corporation Tax Act 2009 (CTA 2009) is a specific corporation tax regime that applies exclusively to...
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Produced in partnership with Anne Fairpo of Temple Tax Chambers 19th May
Practice notes

UK Crown Dependency/Overseas Territory Agreements (CDOT)—FAQs

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

Key tax consequences of an insolvent liquidation

Key tax consequences of an insolvent liquidationThis Practice Note outlines:•the main corporation tax consequences when a UK incorporated company...
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Produced in partnership with Julia Fox of Deloitte LLP and Anthony Davis 19th May
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Practice notes

Corporation tax—connected persons

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
Precedents

Clause—tax gross up—commercial agreements

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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19th May
Practice notes

Section 198 and 199 elections on transactions involving real estate

Section 198 and 199 elections on transactions involving real estateThis Practice Note describes the law and practice relating to elections under...
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Produced in partnership with Martin Wilson 19th May
Practice notes

Taxation of UK LLPs

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 duty

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
Practice notes

Capital reduction demergers

Capital reduction demergersThe reasons why a company might carry out a demerger, and the different ways in which a demerger may be structured, are...
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Produced in partnership with Zoe Feller of Bird & Bird 19th May
Q&As

Corporate redomiciliation—can a non-UK company redomicile into the UK?

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 allowances

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

Most recent Entity classification content

Q&As

On a share buyback carried out by a UK company, one would usually expect any proceeds received by a UK shareholder in excess of the subscription price (broadly speaking) to be taxed as a dividend distribution. Does the same position apply to the proceeds received by a UK shareholder on a buyback carried out by an overseas company?

On a share buyback carried out by a UK company, one would usually expect any proceeds received by a UK shareholder in excess of the subscription price...
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6th Jun
Practice notes

UK tax implications of overseas entity classification and distributions from overseas entities

UK tax implications of overseas entity classification and distributions from overseas entitiesAn overseas entity may be characterised for UK tax...
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Produced in partnership with Michael McGowan 5th Jun
Practice notes

Dual resident investing companies (DRICs)

Dual resident investing companies (DRICs)A company may be resident for tax purposes in two different countries—see Practice Note: When a company is UK...
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Produced in partnership with Michael McGowan 5th Jun
Practice notes

Entity classification case law and HMRC's interpretation

Entity classification case law and HMRC's interpretationIt is necessary to characterise overseas entities for UK tax purposes, as this will determine...
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Produced in partnership with Michael McGowan 5th Jun
Practice notes

Ordinary share capital—what it means and why it matters for UK tax purposes

Ordinary share capital—what it means and why it matters for UK tax purposesThe concept of ordinary share capital is important for UK tax purposes....
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Produced in partnership with Michael McGowan 5th Jun

Popular documents

Insurable interest

Insurable interest

Insurable interestThis Practice Note considers insurable interest, including insurable interest in construction and liability insurance. It also considers insurable interest in subrogation, co-insurance and double insurance and the Insurable Interest Bill.What is insurable interest?‘Insurable

What is a third party debt order (TPDO)?

What is a third party debt order (TPDO)?

What is a third party debt order (TPDO)?This Practice Note explains what a third party debt order (TPDO) (previously known as garnishee orders) is as a means of enforcing a judgment debt, with reference to CPR 72. The order directs a third party who owes money to the judgment debtor to pay that

Scotland: the Accountant in Bankruptcy

Scotland: the Accountant in Bankruptcy

Scotland: the Accountant in BankruptcyThe office of the Accountant in Bankruptcy (AiB) was created by section 156 of the Bankruptcy (Scotland) Act 1856 . Previously, the functions of the AiB were limited but since 1993, with the enactment of the Bankruptcy (Scotland) Act 1993 (B(S)A 1993), the role

Stay of proceedings—when can you apply to stay a claim?

Stay of proceedings—when can you apply to stay a claim?

Stay of proceedings—when can you apply to stay a claim?This Practice Note considers the question of when court proceedings can be stayed. It identifies scenarios in which a party may apply for a stay of proceedings, including to allow for: a jurisdictional challenge; arbitration; an attempt to