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Practice notes
Brexit: As of exit day (31 January 2020) the UK is no longer an EU Member State. However, in accordance with the Withdrawal Agreement, the UK has...
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Produced in partnership with Martin Shah and Gary Barnett of Simmons & Simmons LLP 12th Jan
Practice notes
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...
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9th Nov
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
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
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...
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9th Nov
Practice notes
A damages or compensation payment may attract VAT. This depends on exactly what the payment is for. If it is purely compensatory, it will be outside...
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9th Nov
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 Enterprise Investment Scheme (EIS) is designed to encourage investment in smaller, higher-risk trading companies by offering a range of tax...
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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

Most recent Q&As content

Q&As
Inheritance tax instalment optionSection 227 of the Inheritance Tax Act 1984 (IHTA 1984) provides that where inheritance tax (IHT) is payable in...
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22nd Jan
Q&As
It depends. The size of the land indicates to some extent that this is might be a ‘mixed-use’ transaction for the purposes of stamp duty and land tax...
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Produced in partnership with Sean Randall of Blick Rothenberg 8th Jan
Q&As
Stamp duty is an ad valorem duty which applies to transfers of stock and marketable securities for consideration where the transfer is effected by a...
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Produced in partnership with Mary Ashley of Old Square Tax Chambers 8th Jan
Q&As
It is assumed that the land is in England or Northern Ireland.Stamp duty land tax (SDLT) is payable on the grant of a lease on any premium given by...
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Produced in partnership with Sean Randall of Blick Rothenberg 8th Jan
Q&As
There are a range of issues that could arise for transfer pricing purposes, due to the impact of coronavirus (COVID-19).Intra-group contractsThe...
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Produced in partnership with Kapisha Vyas of Simmons & Simmons and Tomoko Ikawa of Simmons & Simmons 8th Jan
Q&As
There is no specific relief or exemption for non-profit organisations. A relief applies to charities and charitable trusts. ‘Charity’ takes its...
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Produced in partnership with Sean Randall of Blick Rothenberg 8th Jan
Q&As
As a general rule (subject to some exceptions), for stamp duty land tax (SDLT) to apply to a land transaction, there must be chargeable consideration....
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Produced in partnership with Mary Ashley of 15 Old Square 8th Jan
Q&As
In its land transaction return SDLT guidance, HMRC states that:•Code F is to be used for the 'acquisition of any freehold interest in land where no...
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Produced in partnership with Michael Fluss of Keystone Law 8th Jan
Q&As
For demonstrative purposes we will assign each property a value of £400,000 (total consideration, therefore, being £1.2m).Linked transactionsNot all...
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Produced in partnership with Mary Ashley of Old Square Tax Chambers 8th Jan
Q&As
SDRT does not arise on the grant of an option, however, it could arise on an assignment of the option. The grant of an option does not involve a...
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Produced in partnership with Sean Randall of Blick Rothenberg 8th Jan

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