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Practice notes
FORTHCOMING CHANGE: HMRC is consulting (13 July to 10 August 2020) on draft regulations to provide a deduction from a UK entity’s equity and...
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Produced in partnership with Charlotte Sallabank of Katten Muchin Rosenman UK LLP 9th Nov
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
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 9th Nov
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 Gary Barnett, Martin Shah and Simmons & Simmons 9th Nov
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 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 9th Nov
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 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 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 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
Practice notes
This Practice Note:•explains:◦the purpose of the tax indemnity clause that is normally found in a loan agreement, and◦that the standard drafting of...
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9th Nov

Most recent ATED content

Q&As
Annual tax on enveloped dwellings (ATED) applies to high-value UK residential property owned on, or acquired after 1 April 2013, by non-natural...
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29th Sep
Q&As
A number of reliefs and exemptions are available from the annual tax on enveloped dwellings (ATED). One such relief is for property rental...
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28th Sep
Practice notes
What is the annual tax on enveloped dwellings?The annual tax on enveloped dwellings (ATED) was introduced as part of a package of measures aimed at...
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26th Sep
Practice notes
ARCHIVED: This Practice Note has been archived and is not maintained.The annual tax on enveloped dwellings (ATED) was introduced in Finance Act 2013...
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26th Sep
Practice notes
FORTHCOMING CHANGE relating to housing co-operatives: Finance Bill 2020–21 will include provision for a new relief from ATED and the 15% rate of SDLT...
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25th Sep
Practice notes
The basic charge to ATED is explained in Practice Note: ATED—the basics. This Practice Note summarises how ATED is administered and the steps...
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25th Sep

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