Gain invaluable insights and guidance on navigating the intricacies of tax implications during share and asset sales. From due diligence to post-sale adjustments, ensure you are equipped with the knowledge to advise clients with precision and confidence. Stay ahead with expert strategies tailored to mitigate tax liabilities and optimise transactional outcomes.
The following Tax news provides comprehensive and up to date legal information on Court of Appeal—facilitators of VAT fraud can be deregistered even if they make legitimate taxable supplies (Impact Contracting Solutions Limited v HMRC)
The following Tax news provides comprehensive and up to date legal information on FTT decides that an income tax charge arose on the novation of a director’s loan account (Powell v HMRC)
The following Tax news provides comprehensive and up to date legal information on FTT imposes maximum £1m DOTAS penalty for failure to notify (HMRC v Industria Umbrella)
The following Private Client news provides comprehensive and up to date legal information on Ex-solicitor hit with first individual tax avoidance stop notice
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...
VAT treatment of parking facilitiesThis Practice Note is about the VAT treatment of parking facilities.This Practice Note contains references to EU...
The double taxation treaty passport scheme (DTTP scheme)The double taxation treaty passport scheme (DTTP scheme) enables a borrower to apply for and...
What is an intangible fixed asset?Part 8 of the Corporation Tax Act 2009 (CTA 2009) is a specific corporation tax regime that applies exclusively to...
Value shiftingThe value shifting rules are anti-avoidance provisions. They are similar to the rules applying to depreciatory transactions in that they target the artificial transfer of value out of assets as a result of transactions between connected parties. The value shifting rules, however, apply
Client letter explaining the tax covenant and the tax warranties[Law firm’s letterhead][Addressed to client]Acquisition by [name of buyer] (the Buyer) of [name of target company] (the Company) from [name of seller] (the Seller)—tax [deed of ] covenant and tax warrantiesI [attach OR enclose]
Share sale or asset sale—tax considerationsThe sale of a company's business can be structured as either:•a sale of assets owned by the company (an asset sale), or•a sale of shares in the company by its shareholders (a share sale)In an asset sale, a buyer (or, as the case may be, seller) is able to
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 sale of all the shares in a company (the target company) that is:•a private company incorporated in the UK, or•a non-UK incorporated private company
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