Reorganisations, restructuring and insolvency

Effectively managing tax implications in company reorganisations necessitates thorough planning and expert advice. Our resources offer detailed insights, helping tax practitioners maintain compliance and gain strategic benefits during restructuring. Addressing insolvency matters requires a deep knowledge of tax law to minimise risks and achieve positive results. Our platform provides essential tools and practical guidance to support successful resolutions in insolvency situations.

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Demergers Reorganisations and tax Restructuring and insolvency Tax and distressed debt

Latest Tax News

UT rules on extent to which expert evidence could be adduced in VAT dispute (HMRC v Healthspan Ltd)

UT rules on extent to which expert evidence could be adduced in VAT dispute (HMRC v Healthspan Ltd)

Tax analysis: In HMRC v Healthspan Ltd, the Upper Tribunal (UT) allowed HMRC’s appeal relating to the extent to which a supplier of food supplements...

Scottish FTT decides non-residential use, planning status and derelict condition meant Glasgow townhouse and mews properties were non-residential for LBTT purposes (Bagshaw Limited v Revenue Scotland)

Scottish FTT decides non-residential use, planning status and derelict condition meant Glasgow townhouse and mews properties were non-residential for LBTT purposes (Bagshaw Limited v Revenue Scotland)

Tax analysis: In Bagshaw Limited v Revenue Scotland, the Tax Chamber of the First-tier Tribunal for Scotland (Scottish FTT) allowed the taxpayer’s...

Tax weekly highlights—28 May 2026

Tax weekly highlights—28 May 2026

This week's edition of Tax weekly highlights includes: (1) the announcement that measures will be introduced to make the foreign permanent...

UT upholds FTT decision allowing HMRC to amend its statement of case to encompass dividend income not referred to in HMRC’s closure notice (Gwyn-Jones v HMRC)

UT upholds FTT decision allowing HMRC to amend its statement of case to encompass dividend income not referred to in HMRC’s closure notice (Gwyn-Jones v HMRC)

Tax analysis: In Gwyn-Jones v HMRC, the Upper Tribunal (UT) dismissed the taxpayer’s appeal against a decision of the First-Tier Tax Tribunal (FTT)...

Featured Tax content

VAT treatment of damages and compensation payments

VAT treatment of damages and compensation payments

VAT treatment of damages and compensation paymentsA damages or compensation payment may attract VAT. This depends on exactly what the payment is for....

The double taxation treaty passport scheme (DTTP scheme)

The double taxation treaty passport scheme (DTTP scheme)

The double taxation treaty passport scheme (DTTP scheme)The double taxation treaty passport scheme (DTTP scheme) enables a borrower to apply for and...

What are capital allowances and capital expenditure?

What are capital allowances and capital expenditure?

What are capital allowances and capital expenditure?What are capital allowances?Capital allowances are the means by which tax relief is given for some...

If the words ‘exclusive of VAT’ are omitted from the definition of annual rent, but there is a VAT clause stating: ‘Where this lease requires the tenant to pay or provide any amount in respect of a VAT supply to the tenant...that amount will be deemed to be exclusive of VAT...and the tenant shall pay a sum equal to that VAT’, will this be sufficient to charge the tenant VAT? Is there any case law in this area?

If the words ‘exclusive of VAT’ are omitted from the definition of annual rent, but there is a VAT clause stating: ‘Where this lease requires the tenant to pay or provide any amount in respect of a VAT supply to the tenant...that amount will be deemed to be exclusive of VAT...and the tenant shall pay a sum equal to that VAT’, will this be sufficient to charge the tenant VAT? Is there any case law in this area?

If the words ‘exclusive of VAT’ are omitted from the definition of annual rent, but there is a VAT clause stating: ‘Where this lease requires the...

Practice notes

Direct tax treatment of damages and compensation payments

Direct tax treatment of damages and compensation paymentsWhere a dispute is brought to an end by a payment of damages or compensation, whether under a...
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30th May
Practice notes

Residential service charges—VAT implications

Residential service charges—VAT implicationsThis Practice Note is about the VAT treatment of residential service charges.Service charges payable to...
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Produced in partnership with Martin Scammell
13th Oct
Practice notes

Commercial service charges—VAT implications

Commercial service charges—VAT implicationsThis Practice Note is about the VAT treatment of non-residential service charges. General positionService...
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Produced in partnership with Martin Scammell
13th Oct
Practice notes

Taxation of UK LLPs

Taxation of UK LLPsA UK limited liability partnership (LLP) is a body corporate for company law purposes, but is generally taxed as though it were a...
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30th May
Practice notes

Qualifying charitable donations and excess management expenses

Qualifying charitable donations and excess management expensesAll companies within the charge to corporation tax can deduct qualifying charitable...
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30th May
Practice notes

Amortisation of intangible fixed assets

Amortisation of intangible fixed assetsWhere a company acquires (or otherwise incurs capitalised expenditure upon) an intangible fixed asset that...
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30th May
Practice notes

The Budget and Finance Bill process

The Budget and Finance Bill processThe Budget is a Parliamentary event at which the Chancellor of the Exchequer makes important announcements relating...
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30th May
Practice notes

Tax treatment of reorganisations of share capital

Tax treatment of reorganisations of share capitalThis Practice Note is about the meaning of a reorganisation for tax purposes, and the tax treatment...
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2nd Jun
Practice notes

Capital gains—intra-group asset transfers

Capital gains—intra-group asset transfersCompanies which form a group for capital gains purposes are able to transfer assets to one another free of...
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30th May
Practice notes

VAT treatment of intermediaries, agents and disbursements

VAT treatment of intermediaries, agents and disbursementsFor VAT purposes, an intermediary is a person who makes arrangements for, or facilitates, a...
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Produced in partnership with Mark Rowbotham MA FCILT of Portcullis ISC
13th Oct
Practice notes

Taxation of private equity funds—the investors

How are investors in a private equity fund taxed on their share of the profits?This Practice Note sets out how the investors in a typical UK private...
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Produced in partnership with Emily Clark of Travers Smith
13th Oct
Practice notes

Tax and offshore funds—what is an offshore fund?

Taxation of offshore funds—what is an offshore fund?Background to the offshore funds rulesSpecific tax legislation dealing with offshore funds was...
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Produced in partnership with Michael Alliston of Norton Rose Fulbright
13th Oct
Practice notes

Partnerships and capital gains

Partnerships and capital gainsThis Practice Note is about the capital gains tax and corporation tax on chargeable gains treatment of UK general...
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2nd Jun
Practice notes

Tax considerations on a loan agreement—the tax gross up clause

Tax considerations on a loan agreement—the tax gross up clauseIt is standard market practice for loan agreements (also known as facility agreements),...
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Produced in partnership with Eloise Walker of Pinsent Masons
13th Oct
Q&As

For stamp duty relief under section 77 of the Finance Act 1986 (FA 1986) to apply, must the acquiring company in a share for share exchange have a share structure identical to the target company?

For stamp duty relief under section 77 of the Finance Act 1986 (FA 1986) to apply, must the acquiring company in a share for share exchange have a...
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2nd Jun
Practice notes

Property holding structures—direct tax treatment of a Jersey property unit trust (JPUT)

Property holding structures—direct tax treatment of a Jersey property unit trust (JPUT)UK real estate can be held as an investment through an offshore...
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2nd Jun

Popular documents

Restrictions on the use of losses following company takeover

Restrictions on the use of losses following company takeoverPart 14 of the Corporation Tax Act 2010 (CTA 2010) (the Part 14 rules) contains anti-avoidance provisions designed to stop a profitable organisation from reducing its corporation tax liability by acquiring a company with accumulated losses

Tax treatment of reorganisations of share capital

Tax treatment of reorganisations of share capitalThis Practice Note is about the meaning of a reorganisation for tax purposes, and the tax treatment of shareholders in a company that undergoes a reorganisation.A reorganisation of a company's share capital should be tax neutral for its shareholders.

What is the difference between an appeal and a review?

What is the difference between an appeal and a review?What is an appeal?An appeal in insolvency proceedings is no different to an appeal in normal litigation. An appeal will be allowed only if the appeal court is satisfied that the decision of the lower court was 'wrong' or 'unjust because of a

If a beneficiary signs a deed of disclaimer of their share of an estate and the estate pays their legal

If a beneficiary signs a deed of disclaimer of their share of an estate and the estate pays their legal fees, will that count as a PET against their estate?A disclaimer is the refusal of a gift prior to acceptance. The refusal of the gift must take place before the beneficiary accepts any benefit