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Practice notes
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...
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19th May
Practice notes
SDLT—deeds of rectificationStamp duty land tax (SDLT) ceased to apply to any land transaction involving any interests in or over land in Scotland from...
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19th May
Practice notes
VAT—triangulationIP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit transition/implementation period entered into following...
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Produced in partnership with John Fuszard of Sagars Accountants Ltd 19th May
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...
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19th May
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 19th May
Practice notes
Amortisation of intangible fixed assetsWhere a company acquires (or otherwise incurs capitalised expenditure upon) an intangible fixed asset that...
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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...
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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...
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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...
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19th May
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
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
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

Most recent Taxes management and litigation content

Practice notes
HMRC compliance checks, enquiries and discoveryThere are various options open to HMRC when it suspects that tax has not been paid, or has been...
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3rd Aug
Practice notes
Coronavirus (COVID–19)—impact on company filing and administrative proceduresThis Practice Note summarises the key ways in which company filing and...
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2nd Aug
Practice notes
HMRC information powersHMRC's powers to check a person's tax position are in Schedule 36 to the Finance Act 2008.The powers enable HMRC to:•obtain...
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2nd Aug
Q&As
Where an inheritance tax instalment payment is made late, what penalties and interest may be charged by HMRC?Inheritance tax instalment optionSection...
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1st Aug
Q&As
What is the deadline for appealing an FTT decision?In order to make an appeal, a taxpayer must first apply for permission to appeal (PTA). The PTA...
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1st Aug
Q&As
What are considered the leading cases on 'adequate alternative remedy' in judicial review proceedings?Judicial review is considered to be a remedy of...
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Produced in partnership with Jamas Hodivala of Matrix Chambers 1st Aug
Q&As
Is there a time limit for asking for a review of an HMRC decision?In respect of an HMRC decision relating to direct tax, a taxpayer normally has 30...
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1st Aug
Q&As
Does a small or dormant UK company within a large foreign group have to publish a tax strategy under Schedule 19 to the Finance Act 2016?This Q&A...
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1st Aug
Q&As
Is a First-tier Tax Tribunal (FTT) decision binding on HMRC?Although a First-tier Tax Tribunal (FTT) decision is binding on the parties to the...
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1st Aug
Q&As
What are the penalties for late payment of the soft drinks industry levy (SDIL)?Penalties for late paymentA person who is subject to the Soft Drinks...
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1st Aug
Q&As
When a non-UK company has a UK permanent establishment or becomes UK tax resident, how and when must it inform Companies House and HMRC? What happens...
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1st Aug
Q&As
What is the meaning of ‘possession or control’ in the context of the Tribunal Procedure (First-tier Tribunal) (Tax Chamber) Rules 2009, SI 2009/273,...
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1st Aug
Practice notes
Convention rightsThe European Convention on Human Rights (ECHR) was adopted by the Council of Europe in 1950. The ECHR sets out the rights and...
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Produced in partnership with Alexander Campbell of Field Court Chambers 1st Aug
Q&As
Where a discovery amendment has been made to the tax return of a dissolved, trading limited liability partnership under section 30B of the Taxes...
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Produced in partnership with Denis Edwards of Normanton Chambers 1st Aug
Practice notes
Judicial review in the Upper TribunalThe Tribunals, Courts and Enforcement Act 2007 (TCEA 2007) established the First-tier Tribunal (FTT) and the...
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Produced in partnership with Melanie Carter and Alistair Williams of Bates Wells 31st Jul
Practice notes
Judicial review—how to start proceedingsThis Practice Note summarises the procedural stages in a judicial review application and then describes in...
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Produced in partnership with Mathew Purchase of Matrix Chambers and Dr Mirza Ahmad of St Philips Chambers 31st Jul
Q&As
Following the Supreme Court’s decision in Derry, does a notice of enquiry into a tax return have to specify why the enquiry has been opened?HMRC can...
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31st Jul
Practice notes
Judicial review—what it is and when it can be usedWhat is judicial review?Judicial review is a process by which the courts exercise a supervisory...
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Produced in partnership with Mathew Purchase of Matrix Chambers and Dr Mirza Ahmad of St Philips Chambers 31st Jul

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