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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 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
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
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
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
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
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
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
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
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
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
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
Brexit: This Practice Note contains information on subjects impacted by the UK’s withdrawal from the EU. The Taxation (Cross-border Trade) Act 2018,...
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Produced in partnership with John Fuszard of Sagars Accountants Ltd 12th Jan
Practice notes
Stamp duty land tax (SDLT) ceased to apply to any land transaction involving any interests in or over land in Scotland from 1 April 2015. From that...
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9th Nov
Practice notes
FORTHCOMING CHANGE relating to property rich collective investment vehicles and certain investors: HMRC is consulting until 16 December 2020 on draft...
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9th Nov
Practice notes
Part 8 of the Corporation Tax Act 2009 (CTA 2009) is a specific corporation tax regime that applies exclusively to the gains and losses of intangible...
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Produced in partnership with Anne Fairpo of Temple Tax Chambers 12th Jan

Most recent Q&As content

Q&As
As explained in Practice Note: 3 per cent higher rates of SDLT on additional residential properties, the higher 3% rates apply to purchases of...
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7th May
Q&As
Section 30B of the Taxes Management Act 1970 (TMA 1970) permits HMRC, subject to various conditions, to amend a partnership’s tax return so as to...
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Produced in partnership with Denis Edwards of Normanton Chambers 26th Apr
Q&As
The temporary increase in the nil rate band for SDLT applies to transactions with an effective date that falls within the period from 8 July 2020...
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16th Apr
Q&As
None, provided the loan agreement is in Loan Market Association (LMA) standard form.The tax gross-up and indemnity clauses (and their accompanying...
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Produced in partnership with Eloise Walker of Pinsent Masons 15th Apr
Q&As
IP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit transition/implementation period entered into following the UK’s...
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8th Apr
Q&As
‘Financial asset’ is defined in regulation 2 of the Taxation of Securitisation Companies Regulations 2006, SI 2006/3296 (the Securitisation Regs)...
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8th Apr
Q&As
Any material amendment to loan terms could mean it becomes a new loan for FATCA purposes. For this to be the case, the modification has to be...
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Produced in partnership with Ronnie Brown of Burness Paull 8th Apr
Q&As
There are two schools of thought on how Brexit may prevent the Financial Transactions Tax (FTT) proposals from affecting the UK. The first is a policy...
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Produced in partnership with Hilary Barclay of Burges Salmon 8th Apr
Q&As
A targeted anti-avoidance rule (TAAR) was introduced in the Finance Act 2016 (FA 2016) which may impact on a shareholder’s ability to be involved in a...
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7th Apr
Q&As
If no consideration is given in the form of cash, shares (strictly 'stock or marketable securities') or debt, the transfer of the shares would be...
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Produced in partnership with Sean Randall of Blick Rothenberg 31st Mar
Q&As
Stamp duty land tax (SDLT) is charged on chargeable land transactions under section 42 of the Finance Act 2003 (FA 2003).A land transaction is an...
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30th Mar
Q&As
In order to answer this question it is necessary to understand the effect of the VAT Directive in UK law prior to Brexit, before going on to consider...
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25th Mar
Q&As
Post-employment notice pay (PENP) calculationThe first step when considering the taxation of termination payments, including payments in lieu of...
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22nd Mar

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