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Practice notes
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...
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Produced in partnership with Martin Shah and Gary Barnett of Simmons & Simmons LLP 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
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 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 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
Coronavirus (COVID-19): HMRC has stated in its International Manual that if a financial institution cannot meet the FATCA reporting deadline of 31 May...
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Produced in partnership with Ali Kazimi and Chris Orchard of Hansuke Consulting Limited 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
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
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
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
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
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
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
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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9th Nov
Practice notes
A management buyout, or MBO, involves the acquisition of a business by its existing management team usually with the help of private equity financing....
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9th Nov
Practice notes
The international movement of capital rules should be considered whenever:•any non-UK tax resident subsidiary (referred to in this note as a foreign...
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9th Nov

Most recent Taxes management and litigation content

Practice notes
Appeals and applications to the First-tier Tribunal and Upper Tribunal are both significantly affected by the coronavirus (COVID-19) pandemic. This...
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9th Apr
Practice notes
This Practice Note has been written by Anne Redston, Barrister. It is her personal view; she is not authorised to speak for the Tribunals Service or...
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Produced in partnership with Anne Redston 9th Apr
Practice notes
Coronavirus (COVID-19) impact on SAO rules: Because of the effect of coronavirus on businesses, the filing deadline for submitting the SAO...
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9th Apr
Practice notes
FORTHCOMING CHANGE relating to inaccuracy penalties: Following an initial discussion document that was published on 2 February 2015, HMRC is...
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9th Apr
Practice notes
ARCHIVED: This Practice Note has been archived and is not maintained.This Practice Note covers the anti-avoidance measure for transactions in land...
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Produced in partnership with Charles Goddard of Rosetta Tax 9th Apr
Practice notes
HMRC's powers to check a person's tax position are in Schedule 36 to the Finance Act 2008.The powers enable HMRC to:•obtain documents and information,...
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9th Apr
Practice notes
Coronavirus (COVID-19): HMRC has stated in its International Manual that if a person cannot make a report due to difficulties arising from the...
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9th Apr
Practice notes
There are various options open to HMRC when it suspects that tax has not been paid, or has been underpaid. These include:•issuing a determination—this...
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9th Apr
Practice notes
A taxpayer will not be liable for a penalty for late payment of tax if they have a reasonable excuse for failing to comply with the legislation. For...
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Produced in partnership with Philip Rutherford 9th Apr
Practice notes
Sometimes HMRC will come to the view that a taxpayer has paid, or been assessed for, too little tax, but will come to this view at a time when it is...
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Produced in partnership with Cathya Djanogly 9th Apr
Practice notes
FORTHCOMING CHANGE relating to inaccuracy penalties: Following an initial discussion document that was published on 2 February 2015, HMRC is...
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Produced in partnership with Philip Rutherford 9th 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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9th Apr
Practice notes
FORTHCOMING CHANGE relating to inaccuracy penalties: Following an initial discussion document that was published on 2 February 2015, HMRC is...
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Produced in partnership with Philip Rutherford 9th Apr
Practice notes
FORTHCOMING CHANGE relating to inaccuracy penalties: Following an initial discussion document that was published on 2 February 2015, HMRC is...
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Produced in partnership with Philip Rutherford 9th Apr
Practice notes
IP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit transition/implementation period entered into following the UK’s...
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Produced in partnership with Etienne Wong of Old Square Tax Chambers 9th Apr
Practice notes
This Practice Note considers the effect of tax considerations when a court decides how much to award a claimant as damages for a financial loss.The...
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9th Apr
Practice notes
HMRC can investigate suspected tax-related criminal offences in England and Wales using the powers, and subject to the safeguards, in the Police and...
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9th Apr
Practice notes
IP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit transition/implementation period entered into following the UK’s...
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9th Apr
Practice notes
HMRC's information powers in Schedule 36 to the Finance Act 2008 (FA 2008) (see Practice Note: HMRC information powers) are supplemented by...
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9th Apr
Practice notes
FORTHCOMING CHANGE relating to inaccuracy penalties: Following an initial discussion document that was published on 2 February 2015, HMRC is...
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Produced in partnership with Philip Rutherford 9th Apr

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