Reorganisations and tax

View Tax by content type:

Latest Tax News

Featured Tax content

Practice notes
VAT treatment of damages and compensation paymentsFORTHCOMING CHANGE: HMRC is in the process of revising Revenue and Customs Brief 12 (2020) on the...
Read More >
19th May
Practice notes
Amortisation of intangible fixed assetsWhere a company acquires (or otherwise incurs capitalised expenditure upon) an intangible fixed asset that...
Read More >
Produced in partnership with Anne Fairpo of Temple Tax Chambers 19th May
Practice notes
EIS—deferred gain becomes chargeable to CGTCoronavirus (COVID-19): In response to the coronavirus (COVID-19) pandemic, the government introduced a...
Read More >
19th May
Practice notes
Corporation tax—connected personsThis Practice Note looks at the meaning of connected persons within sections 1122 and 1123 of the Corporation Tax Act...
Read More >
19th May
Practice notes
Property holding structures—direct tax treatment of a Jersey property unit trust (JPUT)STOP PRESS relating to property rich collective investment...
Read More >
19th May
Practice notes
VAT on composite suppliesSingle composite supplies vs multiple suppliesWhere a supply comprises a number of different elements with varying VAT...
Read More >
Produced in partnership with Martin Shah and Gary Barnett of Simmons & Simmons LLP 19th May
Practice notes
Commercial service charges—VAT implicationsThis Practice Note is about the VAT treatment of non-residential service charges. General positionService...
Read More >
Produced in partnership with Martin Scammell 19th May
Practice notes
Offshore receipts in respect of intangible property (ORIP)Since 6 April 2019, a person that is neither UK tax resident nor resident in a full treaty...
Read More >
19th May
Precedents
1 Withholding and grossing up 1.1 All sums payable under this [Agreement] by or on behalf of any party (for the...
Read More >
19th May
Practice notes
Section 198 and 199 elections on transactions involving real estateThis Practice Note describes the law and practice relating to elections under...
Read More >
Produced in partnership with Martin Wilson 19th May
Practice notes
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...
Read More >
19th May
Practice notes
Loan capital exemption from stamp dutyDebt which:•qualifies as loan capital (whether it is short or long-term debt), and•satisfies further conditions...
Read More >
19th May
Practice notes
The Budget and Finance Bill processThe Budget is a Parliamentary event at which the Chancellor of the Exchequer makes important announcements relating...
Read More >
19th May
Practice notes
Capital reduction demergersThe reasons why a company might carry out a demerger, and the different ways in which a demerger may be structured, are...
Read More >
Produced in partnership with Zoe Feller of Bird & Bird 19th May
Q&As
Corporate redomiciliation—can a non-UK company redomicile into the UK?It is possible for a non-UK incorporated company to redomicile to the UK....
Read More >
19th May
Practice notes
SDLT group reliefFORTHCOMING CHANGE relating to FA 2008, Sch 36: In its Tax Information and Impact Note (TIIN) on freeports, the government announced...
Read More >
19th May

Most recent Reorganisations and tax content

Practice notes
Stamp duty reliefsFORTHCOMING CHANGE relating to electronic stamping becomes permanent on 19 July 2021: With effect from 19 July 2021, the electronic...
Read More >
23rd Jun
Practice notes
Restrictions on the use of losses following company takeoverPart 14 of the Corporation Tax Act 2010 (CTA 2010) (the Part 14 rules) contains...
Read More >
22nd Jun
Practice notes
Substantial shareholdings exemptionThe substantial shareholdings exemption (SSE) is an exemption from corporation tax on chargeable gains for certain...
Read More >
16th Jun
Q&As
Corporate redomiciliation—can a non-UK company redomicile into the UK?It is possible for a non-UK incorporated company to redomicile to the UK....
Read More >
6th Jun
Q&As
Can a bonus issue of shares in which only one class of shares held by one shareholder benefits, fall within the reorganisation rules in section 126 of...
Read More >
Produced in partnership with Mary Ashley of Old Square Tax Chambers 6th Jun
Q&As
Is there a disposal which creates a chargeable gain when a simple debt (ie not a security) is converted into a qualifying corporate bond by the issue...
Read More >
5th Jun
Q&As
What tax issues should be considered when transferring a non-UK company to a UK company in a share for share exchange?Where a non-UK company is...
Read More >
5th Jun
Q&As
What conditions need to be satisfied for stamp duty takeover relief under FA 1986, s 77?An overview of the stamp duty relief available under section...
Read More >
5th Jun
Practice notes
Capital gains—intra-group asset transfersCompanies which form a group for capital gains purposes are able to transfer assets to one another free of...
Read More >
5th Jun
Practice notes
Tax treatment of reorganisations of share capitalThis Practice Note is about the meaning of a reorganisation for tax purposes, and the tax treatment...
Read More >
5th Jun
Practice notes
Transactions in securitiesThis Practice Note covers the transactions in securities (TiS) rules relating to the avoidance of both income tax and...
Read More >
5th Jun
Practice notes
Tax treatment of conversions of securitiesThe conversion of a company's securities should be treated as a tax neutral reorganisation. The conversion...
Read More >
5th Jun
Practice notes
Transactions in securities—clearances and administrationThis Practice Note covers the:•clearance procedure, and•administrative rules (enquiries,...
Read More >
5th Jun
Practice notes
Transfer of a trade under common ownershipSometimes the restructuring of a business will involve a company transferring an existing trade to a...
Read More >
5th Jun
Practice notes
Tax reliefs for schemes of reconstructionTax relief for chargeable gains is available for both:•the shareholders of a company, and•the company...
Read More >
5th Jun
Practice notes
Share for share exchanges and qualifying corporate bonds (QCBs)Some company acquisitions that involve a corporate buyer will be structured so that the...
Read More >
5th Jun
Practice notes
Share for share exchanges and schemes of reconstruction—anti-avoidance rulesThis Practice Note is about the tax anti-avoidance rules that apply to a...
Read More >
5th Jun

Popular documents