Plant and machinery allowances are the most widely used form of capital allowance. Plant and machinery is often (wrongly) interpreted as if the terms...
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...
It is standard market practice for loan agreements (also known as facility agreements), whether bilateral or syndicated, to:•prohibit a borrower from...
Coronavirus (COVID-19): HMRC has stated in its International Manual that if a financial institution cannot meet the FATCA reporting deadline of 31 May...
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...
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...
Overdrafts, term loans and revolving credit facilitiesThree common types of loan facility are:•overdrafts•term loans, and•revolving credit facilities...
The regime for property authorised investment funds (PAIFs, or as HMRC use in regulations and their published guidance, Property AIFs)) was introduced...
A management buyout, or MBO, involves the acquisition of a business by its existing management team usually with the help of private equity financing....
The international movement of capital rules should be considered whenever:•any non-UK tax resident subsidiary (referred to in this note as a foreign...
This practice note provides a broad overview of the application of the Foreign Account Tax Compliance Act (FATCA) to fund structures in the UK.Where...
The Hiring Incentives to Restore Employment Act (the HIRE Act) include provisions that give the US Internal Revenue Service (the IRS) administrative...
What are the CDOT agreements?The UK entered into agreements with its three Crown Dependencies (CDs) (Guernsey, Jersey and the Isle of Man), together...
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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