Reorganisations, restructuring and insolvency

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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
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 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
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
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
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
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
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
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 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 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
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
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
Brexit: This Practice Note contains information on subjects impacted by the UK’s withdrawal from the EU. The Taxation (Cross-border Trade) Act 2018,...
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Produced in partnership with John Fuszard of Sagars Accountants Ltd 12th Jan
Practice notes
Stamp duty land tax (SDLT) ceased to apply to any land transaction involving any interests in or over land in Scotland from 1 April 2015. From that...
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9th Nov
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 12th Jan

Most recent Reorganisations, restructuring and insolvency content

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 5th May
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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4th May
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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4th May
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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4th May
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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26th Apr
Practice notes
FORTHCOMING CHANGE: Finance Bill 2021 amends the definition of a change of ownership so that the ‘wider’ definition (referred to below), that...
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26th Apr
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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21st Apr
Practice notes
This Practice Note covers the:•clearance procedure, and•administrative rules (enquiries, counteraction notices and appeals)relating to the...
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12th Apr
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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Produced in partnership with Phillip Taylor of Sidley Austin LLP and Chris Laughton of Mercer & Hole Chartered Accountants 9th Apr
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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Produced in partnership with John Baldry of Temple Tax Chambers 9th Apr
Practice notes
This Practice Note is about the tax implications of liquidation demergers, also known as section 110 demergers, after section 110 of the Insolvency...
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9th Apr
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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9th Apr
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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9th Apr
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 Apr
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 9th Apr
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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9th Apr
Practice notes
This Practice Note outlines how a taxable person who has accounted for and paid VAT on a supply, but who is not paid the price for that supply, may...
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Produced in partnership with Etienne Wong of Old Square Tax Chambers 9th Apr
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 9th Apr
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 9th Apr
Practice notes
This Practice Note covers the transactions in securities (TiS) rules relating to the avoidance of both income tax and corporation tax.The TiS rules...
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9th Apr

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