Direct tax treatment of property ownership

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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
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
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 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 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 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
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
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
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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25th Nov
Q&As
There are various UK tax issues to consider on the merger of two non-UK companies holding UK residential property.It is important to understand the...
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29th Sep
Q&As
This Q&A refers to a UK resident and domiciled individual; a property that is not the individual’s principal private residence; and profits or gains...
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29th Sep
Q&As
The rules introduced in Finance Act 2016 (FA 2016) that tax Profits from trading in and developing UK land (transactions in UK land) did not make any...
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29th Sep
Q&As
Where a property-rich entity is trading before and after a disposal of an interest in it and the UK land is used in the qualifying trade, any indirect...
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29th Sep
Q&As
For the purposes of this Q&A we have assumed that:•the management company owns the freehold of the block•all residents are shareholders of the...
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28th Sep
Q&As
For the purposes of this Q&A, we have assumed that the properties are in the UK. We have further assumed that the company is not a property trader or...
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28th Sep
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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26th Sep
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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26th Sep
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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26th Sep
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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26th Sep
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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26th Sep
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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26th Sep
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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26th Sep
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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26th Sep
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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26th Sep
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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26th Sep
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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26th Sep

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