Direct tax treatment of property ownership

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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
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
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 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
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 Direct tax treatment of property ownership content

Practice notes
The distinction between trading and investment is key in determining the correct tax treatment of transactions involving land or property. Land, more...
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9th Apr
Practice notes
At Budget 2016 the government announced rules to tax profits from trading in and developing UK land. The legislation was added to Finance Bill 2016...
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9th Apr
Practice notes
In many real estate sale and purchase transactions, the consideration for the sale will include an element of overage. Overage can be structured in a...
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Produced in partnership with Charles Goddard of Rosetta Tax 9th Apr
Practice notes
ARCHIVED: This Practice Note has been archived and is not maintained.This Practice Note covers the anti-avoidance measure for transactions in land...
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Produced in partnership with Charles Goddard of Rosetta Tax 9th Apr
Practice notes
Swap arrangements are often entered into in connection with financing UK real estate, most commonly to hedge against interest rate fluctuations. For...
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9th Apr
Practice notes
This Practice Note looks at what constitutes a UK permanent establishment (PE) in the context of a trade of dealing in property. Prior to 5 July 2016...
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Produced in partnership with Charles Goddard of Rosetta Tax 9th Apr
Practice notes
A UK company that has incurred a loss in its UK property business for an accounting period can, in general, use that loss by:•setting it against total...
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9th Apr
Practice notes
For a UK taxpayer carrying on a real estate-related business in the UK, whether it be trading or investing in land, the tax treatment of their...
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Produced in partnership with Charles Goddard of Rosetta Tax 9th Apr
Practice notes
This Practice Note covers the extent to which interest expenditure is deductible for income tax payers and corporation tax payers investing in UK real...
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9th Apr
Practice notes
The charge to UK income tax applies to the profits of both a UK and overseas property business. A property business is one that generates income from...
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9th Apr
Practice notes
The charge to UK income tax applies to the profits of both a UK and overseas property business.A property business is one which generates income from...
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9th Apr
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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9th Apr
Practice notes
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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Produced in partnership with Charles Goddard of Rosetta Tax 9th Apr
Practice notes
Whether a property transaction is an investment or trading (ie dealing) activity is of key importance to each of the parties to the transaction since...
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9th Apr
Practice notes
Many investors in UK property are based outside the UK. The UK real estate sector is attractive to a range of investors, from high net worth...
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Produced in partnership with Charles Goddard of Rosetta Tax 9th Apr
Practice notes
ARCHIVED: This Practice Note gives an overview of the non-resident capital gains tax (NRCGT) charge that applied to certain non-UK resident persons...
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Produced in partnership with Alison Cartin of Taylor Wessing LLP 9th Apr
Practice notes
STOP PRESS relating to property rich collective investment vehicles and certain investors: HMRC consulted until 16 December 2020 on regulations that...
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6th Apr
Practice notes
The Non-resident Landlords Scheme (NRL Scheme) requires income tax at the basic rate to be deducted from rental payments due to non-resident landlords...
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3rd Mar
Practice notes
The charge to UK corporation tax applies to the profits of both UK and overseas property business.A property business is one that generates income...
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3rd Mar
Practice notes
A key concern for those engaged in a trade of developing property situated in the UK is the imposition of UK taxation on the profits of that trade....
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Produced in partnership with Charles Goddard of Rosetta Tax 25th Feb

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