Restructuring and insolvency

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Practice notes
VAT on composite suppliesSingle composite supplies vs multiple suppliesWhere a supply comprises a number of different elements with varying VAT...
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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...
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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...
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19th May
Practice notes
FATCA in the UK—the UK:US Intergovernmental Agreement: an outlineIP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit...
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Produced in partnership with Ali Kazimi and Chris Orchard of Hansuke Consulting Limited 19th May
Practice notes
Tax considerations on a loan agreement—the tax gross up clauseIP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit...
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Produced in partnership with Eloise Walker of Pinsent Masons 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...
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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...
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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...
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Produced in partnership with Martin Wilson 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...
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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...
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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...
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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....
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19th May
Practice notes
Why have a tax covenant?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...
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19th May
Practice notes
R&D capital allowancesFORTHCOMING CHANGE: At Spring Budget 2021, the government announced a wide-ranging review of research and development (R&D)...
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Produced in partnership with Anne Fairpo of Temple Tax Chambers 19th May
Practice notes
Transfer of a trade under common ownershipSometimes the restructuring of a business will involve a company transferring an existing trade to a...
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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...
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19th May

Most recent Restructuring and insolvency content

Practice notes
VAT bad debt reliefThis 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...
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Produced in partnership with Etienne Wong of Old Square Tax Chambers 16th Sep
Q&As
If a creditor claims inclusive of value added tax (VAT) on their proof of debt, can the office holder compel them to reclaim their VAT and only admit...
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Produced in partnership with Christopher Snell of New Square Chambers 22nd Aug
Practice notes
Key tax considerations relevant to company voluntary arrangements (CVAs) with creditorsThis Practice Note outlines the main tax implications where a...
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Produced in partnership with Anthony Davis and Julia Fox of Deloitte LLP 22nd Aug
Practice notes
Key tax consequences of an administrationThis Practice Note outlines:•the main corporation tax consequences when a UK incorporated company goes into...
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Produced in partnership with Anthony Davis and Julia Fox of Deloitte LLP 22nd Aug
Practice notes
Key tax consequences of an insolvent liquidationThis Practice Note outlines:•the main corporation tax consequences when a UK incorporated company...
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Produced in partnership with Julia Fox of Deloitte LLP and Anthony Davis 22nd Aug
Practice notes
Taxation in corporate insolvency—the principal issues in outlineTaxation and insolvencyThere are relatively few specific rules governing the UK...
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Produced in partnership with David L. Irvine of Goodwin, Nathan Langford of Kirkland & Ellis International LLP and Philip Ridgway of Temple Tax Chambers 22nd Aug
Practice notes
Waterfall of payments—a comparative guideLiquidationThe order of distribution in liquidation, following the realisation of security by fixed charge...
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Produced in partnership with South Square Chambers 18th Aug
Practice notes
Receivers and VATFORTHCOMING CHANGES relating to insolvency and tax: Finance Act 2020 introduces provisions where:•HMRC becomes a secondary...
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Produced in partnership with John Baldry of Temple Tax Chambers 16th Aug
Q&As
In many asset sales the apportionment of the business' sale price apportions £1.00 to the business' lease, why is this and how is this apportionment...
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16th Aug
Q&As
Does HMRC provide any guidance on stamp duty reserve tax and transfers by a liquidator to shareholders when a business is wound up?HMRC guidance...
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16th Aug
Q&As
Are the tax implications of a company liquidation the same as where the company is voluntarily struck off?Any company, whether public or private, can...
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16th Aug
Q&As
Is stamp duty payable in respect of a share for share exchange undertaken as part of a section 110 demerger? Since UK stamp duty applies to...
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16th Aug
Q&As
Is a shareholder prevented from future involvement in a trade where entrepreneurs’ relief has been claimed on a distribution of assets as a part of a...
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16th Aug
Practice notes
Joint and several liability of company directors and certain other individuals for tax debts of companies and limited liability partnershipsThe...
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Produced in partnership with David L. Irvine of Goodwin and Nathan Langford of Kirkland & Ellis International LLP 15th Aug
Practice notes
Key tax considerations relevant to appointment of a fixed charge receiverThis Practice Note:•outlines the main UK tax provisions that apply where a...
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Produced in partnership with Anthony Davis and Julia Fox of Deloitte LLP 15th Aug
Practice notes
Liquidation demergersThis Practice Note is about the tax implications of liquidation demergers, also known as section 110 demergers, after section 110...
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15th Aug

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