Reorganisations, restructuring and insolvency

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Practice notes
FORTHCOMING CHANGE relating to SDLT for non-residents buying residential property: As announced at Budget 2018, confirmed at Spring Budget 2020 and...
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23rd Oct
Practice notes
Once is has been determined that there is a notifiable transaction for SDLT purposes, it should be considered whether any reliefs or exemptions are...
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21st Oct
Practice notes
The sale of a 'business' is really a sale of assets bundled together. VAT would therefore be charged on the transfer of each asset in accordance with...
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Produced in partnership with Cathya Djanogly 8th Oct
Practice notes
Provisions in the Finance (No 2) Act 2017 (F(No 2)A 2017) made considerable reforms to the rules governing what companies can do with carried-forward...
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26th Sep
Practice notes
FORTHCOMING CHANGE: HMRC is consulting on changes to the hybrid mismatch rules to ensure that they work proportionately and as intended. Amendments...
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26th Sep
Practice notes
This Practice Note considers the steps to take in relation to SDLT once it is established there is a chargeable transaction. For details about the...
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26th Sep
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 26th Sep
Practice notes
FORTHCOMING CHANGE relating to the modernisation of stamp taxes on shares framework: The government is asking for views on the principles and design...
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26th Sep
Practice notes
This Practice Note is about the issues that arise on a transfer of a going concern involving land and buildings.A transfer of a going concern (TOGC)...
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26th Sep
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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26th Sep
Practice notes
BackgroundOn 6 July 2018, the government published draft legislation to be included in Finance Bill 2019 (formally the Finance (No 3) Bill 2017–19,...
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26th Sep
Practice notes
Stamp duty land tax (SDLT) is charged on chargeable land transactions. Consequently, the concept of a land transaction and what this encompasses is...
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25th Sep
Practice notes
FORTHCOMING CHANGE: Finance Bill 2020–2021 will contain two technical amendments to the CIR rules to ensure the regime works as intended. The first is...
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25th Sep
Practice notes
If an exemption from stamp duty applies, a document (ie an instrument of transfer) which would otherwise be subject to UK stamp duty is exempt from...
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25th Sep
Practice notes
Unless an exemption or relief applies, payments of:•yearly interest (or amounts that are treated by tax legislation as payments of yearly interest),...
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25th Sep
Practice notes
The amount of stamp duty land tax (SDLT) payable on a chargeable transaction is determined by reference to the 'chargeable consideration' for the...
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25th Sep

Most recent Reorganisations, restructuring and insolvency content

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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25th Sep
Practice notes
This Practice Note outlines the tax issues that are relevant where creditors seek to enforce their security over the assets of a company, or corporate...
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25th Sep
Practice notes
The economic climate can lead to instances of distressed debt portfolios changing hands. In such a climate, typically banks seek to reduce their...
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25th Sep
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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25th Sep
Practice notes
The conversion of a company's securities should be treated as a tax neutral reorganisation. The conversion is treated as not involving any disposal of...
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25th Sep
Practice notes
This Practice Note covers: •what arrangements under Insolvency Act 1986 (IA 1986), s 110 (a s 110 arrangement) is (see: What is a s 110...
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25th Sep
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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25th Sep
Practice notes
This Practice Note is about the tax anti-avoidance rules that apply to a share for share (or share for loan note) exchange or a scheme of...
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25th Sep
Practice notes
This Practice Note is about the following aspects of the tax rules on statutory (ie dividend) demergers:•the anti-avoidance rules concerning...
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25th Sep
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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25th Sep
Practice notes
This Practice Note is about the conditions that a statutory (ie dividend) demerger, whether direct or indirect, must satisfy if it is to qualify as an...
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25th Sep
Precedents
HMRC—Stamp Office[insert HMRC Stamp Office address]Application for stamp duty group relief under section 42 of the Finance Act 1930 (as amended)in the...
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26th Sep
Precedents
[Team Leader][insert HMRC address][insert date]Application for clearance[s] in advance under section 1091 of the Corporation Tax Act 2010[ and...
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26th Sep
Practice notes
FORTHCOMING CHANGES relating to insolvency and tax: Finance Act 2020 introduces provisions where:•HMRC becomes a secondary preferential unsecured...
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26th Sep
Precedents
HM Revenue and Customs[insert address][insert date]Election under section 171A(4) of the Taxation of Chargeable Gains Act 1992This election is made...
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26th Sep
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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26th Sep
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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26th Sep
Practice notes
Companies which form a group for capital gains purposes are able to transfer assets to one another free of corporation tax on chargeable gains.Each...
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26th Sep
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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26th Sep
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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26th Sep

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