Reorganisations, restructuring and insolvency

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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 12th Jan
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
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
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
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
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 Reorganisations, restructuring and insolvency content

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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19th Jan
Practice notes
This Practice Note covers the:•clearance procedure, and•administrative rules (enquiries, counteraction notices and appeals)relating to the...
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15th Jan
Practice notes
STOP PRESS relating to insolvency and tax: Finance Act 2020 introduced provisions where:•with effect for business insolvencies that commence on or...
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Produced in partnership with Julia Fox of Deloitte LLP and Anthony Davis 15th Jan
Practice notes
Coronavirus (COVID-19) impact on stamp duty process: During the coronavirus outbreak, the Stamp Office is temporarily only accepting electronic...
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15th Jan
Practice notes
Tax relief for chargeable gains is available for both:•the shareholders of a company, and•the company itselfunder a scheme of reconstruction provided...
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15th Jan
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...
Read More >
Produced in partnership with Jenny Doak of Weil Gotshal & Manges LLP 15th Jan
Practice notes
Sometimes the restructuring of a business will involve a company transferring an existing trade to a different company under the same ownership.Where...
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15th 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 15th Jan
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 Etienne Wong of Old Square Tax Chambers 15th Jan
Practice notes
This Practice Note:•outlines the main UK tax provisions that apply where a fixed charge receiver sells assets owned by a company, and•answers the...
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Produced in partnership with Anthony Davis and Julia Fox of Deloitte LLP 15th Jan
Practice notes
This Practice Note outlines:•the main corporation tax consequences when a UK incorporated company goes into an administration process in the UK,...
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Produced in partnership with Anthony Davis and Julia Fox of Deloitte LLP 15th Jan
Practice notes
Taxation and insolvencyThere are relatively few specific rules governing the UK taxation of companies that are subject to insolvency procedures. The...
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Produced in partnership with David L. Irvine, Nathan Langford of Kirkland & Ellis International LLP and Philip Ridgway of Temple Tax Chambers 15th Jan
Practice notes
The substantial shareholdings exemption (SSE) is an exemption from corporation tax on chargeable gains for certain share disposals by companies. The...
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15th Jan
Practice notes
Some company acquisitions that involve a corporate buyer will be structured so that the consideration payable is the issue of new shares and/or loan...
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15th Jan
Practice notes
This Practice Note outlines the main tax implications where a company implements a company voluntary arrangement (CVA) under Part I of the Insolvency...
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Produced in partnership with Anthony Davis and Julia Fox of Deloitte LLP 15th Jan
Practice notes
Part 14 of the Corporation Tax Act 2010 (CTA 2010) (the Part 14 rules) contains anti-avoidance provisions designed to stop a profitable organisation...
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15th Jan
Practice notes
This Practice Note is about the tax implications of a statutory demerger.It is possible to carry out a demerger by a company (the target company)...
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15th Jan
Practice notes
This Practice Note outlines the tax issues that should be considered when a company seeks to restructure its external debt obligations.Other Practice...
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Produced in partnership with Jenny Doak of Weil Gotshal & Manges LLP 15th Jan
Practice notes
This Practice Note is about the meaning of a reorganisation for tax purposes, and the tax treatment of shareholders in a company that undergoes a...
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15th Jan
Practice notes
A demerger means the separation of a company’s business into two or more parts, typically carried on by successor companies under the same ownership...
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Produced in partnership with Zoe Feller of Bird & Bird and Robert Langston of Saffery Champness 15th Jan

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