Plant and machinery allowances are the most widely used form of capital allowance. Plant and machinery is often (wrongly) interpreted as if the terms...
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...
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:...
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...
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 glossary sets out the meaning of key terms used when looking at tax issues that arise within the private equity and venture capital industry. For...
The income-based carried interest (IBCI) rules form part of the legislation which governs the tax treatment of rewards received by fund managers. The...
This Practice Note looks at tax issues arising on money borrowed by the acquisition group to finance a private equity-backed buyout.In the context of...
This Practice Note deals with private equity-backed management buyouts (MBOs) and examines the tax issues arising for UK managers on the operation of...