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Latest Tax News

Supreme Court finds taxpayer had not made deliberate inaccuracy and that staleness is not relevant to discovery (HMRC v Raymond Tooth)

The following Private Client news provides comprehensive and up to date legal information on Supreme Court finds taxpayer had not made deliberate inaccuracy and that staleness is not relevant to discovery (HMRC v Raymond Tooth)

Tax weekly highlights—13 May 2021

The following Tax news provides comprehensive and up to date legal information on Tax weekly highlights—13 May 2021

Contracts—‘Reasonable detail’ in notice clause determined by business purpose (Dodika Ltd and others v United Luck Group Holdings Ltd)

The following Commercial news provides comprehensive and up to date legal information on Contracts—‘Reasonable detail’ in notice clause determined by business purpose (Dodika Ltd and others v United Luck Group Holdings Ltd)

Taxpayer’s Ramsay argument fails before the Court of Appeal (Khan v HMRC)

The following Tax news provides comprehensive and up to date legal information on Taxpayer’s Ramsay argument fails before the Court of Appeal (Khan v HMRC)

Featured Tax content

Tax considerations on a loan agreement—the tax indemnity clause

This Practice Note:•explains:◦the purpose of the tax indemnity clause that is normally found in a loan agreement, and◦that the standard drafting of...

International movement of capital

The international movement of capital rules should be considered whenever:•any non-UK tax resident subsidiary (referred to in this note as a foreign...

Management buyouts—summary of tax issues for management

A management buyout, or MBO, involves the acquisition of a business by its existing management team usually with the help of private equity financing....

Clause—tax gross up—commercial agreements

1 Withholding and grossing up 1.1 All sums payable under this [Agreement] by or on behalf of any party (for the...

Practice notes

Value shifting

The value shifting rules are anti-avoidance provisions. They are similar to the rules applying to depreciatory transactions in that they target the...

9th Nov

Practice notes

Property authorised investment funds (PAIFs)—summary

The regime for property authorised investment funds (PAIFs, or as HMRC use in regulations and their published guidance, Property AIFs)) was introduced...

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

VAT treatment of damages and compensation payments

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...

9th Nov

In-house

Practice notes

Direct tax treatment of damages and compensation payments

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...

9th Nov

Practice notes

What is a tax determination?

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...

Produced in partnership with Philip Rutherford 12th Jan

Practice notes

Schemes of reconstruction defined

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...

9th Nov

Practice notes

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

It is standard market practice for loan agreements (also known as facility agreements), whether bilateral or syndicated, to:•prohibit a borrower from...

Produced in partnership with Eloise Walker of Pinsent Masons 12th Jan

Practice notes

Section 198 and 199 elections on transactions involving real estate

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...

Produced in partnership with Martin Wilson 12th Jan

Practice notes

Capital reduction demergers

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:...

Produced in partnership with Zoe Feller of Bird & Bird 12th Jan

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 sale of all the shares...

9th Nov

Practice notes

VAT on composite supplies

Brexit: As of exit day (31 January 2020) the UK is no longer an EU Member State. However, in accordance with the Withdrawal Agreement, the UK has...

Produced in partnership with Martin Shah and Gary Barnett of Simmons & Simmons LLP 12th Jan

Practice notes

Unilateral relief for foreign tax

Unilateral relief, like double tax relief, aims to relieve double taxation. Subject to certain conditions being satisfied and specific limits,...

9th Nov

Practice notes

VAT—triangulation

Brexit: This Practice Note contains information on subjects impacted by the UK’s withdrawal from the EU. The Taxation (Cross-border Trade) Act 2018,...

Produced in partnership with John Fuszard of Sagars Accountants Ltd 12th Jan

Practice notes

SDLT—deeds of rectification

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...

9th Nov

Practice notes

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

FORTHCOMING CHANGE relating to property rich collective investment vehicles and certain investors: HMRC is consulting until 16 December 2020 on draft...

9th Nov

Practice notes

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 the gains and losses of intangible...

Produced in partnership with Anne Fairpo of Temple Tax Chambers 12th Jan

Most recent Stamp and transfer taxes content

Practice notes

SDLT and partnerships—anti-avoidance and reliefs

SDLT and partnerships—anti-avoidance and reliefsThis Practice Note gives details of stamp duty land tax (SDLT) anti-avoidance rules and SDLT reliefs...

Produced in partnership with Kevin Griffin 15th May

Practice notes

SDLT—common lease transactions

SDLT—common lease transactionsThis Practice Note provides an overview of the stamp duty land tax (SDLT) treatment of the following common lease...

15th May

Practice notes

SDLT—pre-completion transactions

SDLT—pre-completion transactionsIt was established under the stamp duty rules that relief should be available to a person who has contracted to buy an...

15th May

Practice notes

SDLT and partnerships—transfers from a partnership

SDLT and partnerships—transfers from a partnershipThis Practice Note explains the special stamp duty land tax (SDLT) rules which apply when an...

15th May

Practice notes

Scotland: Land and buildings transaction tax (LBTT)—the basics

Scotland: Land and buildings transaction tax (LBTT)—the basicsLand and buildings transaction tax (LBTT) replaced stamp duty land tax (SDLT) in...

Produced in partnership with Ronnie Brown of Burness Paull 15th May

Scottish Law

Practice notes

Higher rate SDRT and stamp duty charges

Higher rate SDRT and stamp duty chargesFORTHCOMING CHANGE relating to the modernisation of stamp taxes on shares framework: The government is asking...

15th May

Practice notes

SDLT—notifiable transactions

SDLT—notifiable transactionsThis Practice Note considers the steps to take in relation to SDLT once it is established there is a chargeable...

15th May

Practice notes

Stamp duty reliefs

Stamp duty reliefsCoronavirus (COVID-19) impact on stamp duty process: During the coronavirus outbreak, the Stamp Office is temporarily only accepting...

15th May

Practice notes

Stamp duty on transfers—scope, administration and enforcement

Stamp duty on transfers—scope, administration and enforcementCoronavirus (COVID-19) impact on stamp duty process: During the coronavirus outbreak, the...

15th May

Practice notes

Stamp duty and SDRT on the sale of certificated registered UK shares

Stamp duty and SDRT on the sale of certificated registered UK sharesCoronavirus (COVID-19) impact on stamp duty process: During the coronavirus...

15th May

Practice notes

3 per cent higher rates of SDLT on additional residential properties

3 per cent higher rates of SDLT on additional residential propertiesThe higher 3% rates of stamp duty land tax (SDLT) apply to:•purchases of certain...

15th May

Practice notes

SDLT—land transactions, chargeable interests and chargeable transactions

SDLT—land transactions, chargeable interests and chargeable transactionsStamp duty land tax (SDLT) is charged on chargeable land transactions....

15th May

Practice notes

Wales: Land transaction tax (LTT)—particular transactions and taxpayers

Wales: Land transaction tax (LTT)—particular transactions and taxpayersLand transaction tax (LTT) replaced stamp duty land tax (SDLT) in Wales with...

Produced in partnership with Andrew Evans 15th May

Practice notes

SDLT—reconstruction and acquisition reliefs

SDLT—reconstruction and acquisition reliefsFORTHCOMING CHANGE relating to FA 2008, Sch 36: In its Tax Information and Impact Note (TIIN) on freeports,...

15th May

Practice notes

SDLT—section 75A: the SDLT GAAR

SDLT—section 75A: the SDLT GAARWhy are the SDLT anti-avoidance provisions important?The stamp duty land tax (SDLT) anti-avoidance provisions set out...

15th May

In-house

Practice notes

Exemptions from the principal charge to SDRT

Exemptions from the principal charge to SDRTExecutive summaryAn agreement to transfer chargeable securities for consideration (or, in certain...

15th May

Practice notes

Rates of SDLT

Rates of SDLTThis Practice Note considers the various rates of stamp duty land tax (SDLT), including rates of SDLT applicable on transactions...

15th May

Practice notes

Disclosure of tax avoidance schemes—SDLT

Disclosure of tax avoidance schemes—SDLTThis Practice Note describes the rules on the disclosure of tax avoidance schemes (DOTAS) applying to stamp...

15th May

Practice notes