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Practice notes
Unilateral relief, like double tax relief, aims to relieve double taxation. Subject to certain conditions being satisfied and specific limits,...
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9th Nov
Practice notes
Plant and machinery allowances are the most widely used form of capital allowance. Plant and machinery is often (wrongly) interpreted as if the terms...
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Produced in partnership with Martin Wilson 9th Nov
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 Gary Barnett, Martin Shah and Simmons & Simmons 9th Nov
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 9th Nov
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 9th Nov
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 9th Nov
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 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 regime for property authorised investment funds (PAIFs, or as HMRC use in regulations and their published guidance, Property AIFs)) was introduced...
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Produced in partnership with Martin Shah 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
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
Practice notes
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...
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9th Nov

Most recent Taxes management and litigation content

Precedents
Filed on behalf of the [insert party eg [Claimant OR Appellant] or [Defendant OR Respondents]]Number of witness statement: [insert eg first]Date:...
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28th Nov
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 25th Nov
Practice notes
STOP PRESS: The Supreme Court has, on a majority, allowed HMRC’s appeal in the latest stage of the Franked Investment Income (FIIGLO) litigation,...
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Produced in partnership with Etienne Wong of Old Square Tax Chambers 25th Nov
Practice notes
ARCHIVED: This archived Practice Note is not being maintained. It tracked the passage of the Bill through Parliament to its publication as an Act, and...
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25th Nov
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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23rd Nov
Practice notes
STOP PRESS: The All-Party Parliamentary Group on Anti-Corruption & Responsible Tax, which was established in June 2020 is currently researching more...
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19th Nov
Practice notes
This Practice Note considers:•requirement to correct and failure to correct penalties•penalties for offshore matters or offshore transfers•offshore...
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Produced in partnership with Jason Collins and Catherine Robins of Pinsent Masons 18th Nov
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 18th Nov
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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18th Nov
Practice notes
Companies House has issued guidance for its customers, suppliers and employees on a number of temporary changes it has made to its usual procedures...
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18th Nov
Practice notes
BackgroundThis Practice Note considers the impact that the coronavirus (COVID-19) pandemic may have on the preparation and filing of a company’s...
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18th Nov
Practice notes
Effective preparation of bundles is an essential element of a smooth, orderly hearing and something which practitioners should keep in clear focus as...
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Produced in partnership with Ross McLeod, Christopher Humby, Leo Kitchen and Damian Curran of Quinn Emanuel Urquhart & Sullivan UK LLP 17th Nov
Practice notes
This Practice Note is about the following aspects of the tax rules on statutory (ie dividend) demergers:•the anti-avoidance rules concerning...
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16th Nov
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 23rd Oct
Practice notes
This Practice Note discusses the two ‘failure to prevent’ corporate criminal offences created by the Criminal Finances Act 2017 (CFA 2017):•CFA 2017,...
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Produced in partnership with Rhys Meggy of QEB Hollis Whiteman 20th Oct
Precedents
[Team Leader][insert HMRC address][insert date]Application for clearances in advance under [section[s] 138[ and 139(5)] Taxation of Chargeable Gains...
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20th Oct
Practice notes
This Practice Note covers the:•clearance procedure, and•administrative rules (enquiries, counteraction notices and appeals)relating to the...
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19th Oct
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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13th Oct
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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12th Oct

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