Penalties, interest and time limits

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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 12th Jan
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
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

Most recent Penalties, interest and time limits content

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
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
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...
Read More >
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...
Read More >
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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9th Apr
Practice notes
FORTHCOMING CHANGE relating to inaccuracy penalties: Following an initial discussion document that was published on 2 February 2015, HMRC is...
Read More >
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...
Read More >
Produced in partnership with Philip Rutherford 9th Apr
Practice notes
FORTHCOMING CHANGE: HMRC has consulted on proposals to amend the rules in Schedule 41 to the Finance Act 2008 on penalties for failure to notify, as...
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Produced in partnership with Philip Rutherford 9th Apr
Practice notes
FORTHCOMING CHANGE: HMRC has consulted on proposals to amend the rules in Schedule 41 to the Finance Act 2008 on penalties for failure to notify, as...
Read More >
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
ARCHIVED: This Practice Note has been archived and is not maintained. HMRC has the power to charge a penalty where there are errors in, or omissions...
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Produced in partnership with Philip Rutherford 9th Apr
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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9th Apr
Practice notes
What is the requirement to correct?The legislation for the requirement to correct (RTC) regime is set out in section 67 and Schedule 18 to the Finance...
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9th Apr
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 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 Nicholas Griffin QC and Tom Broomfield of QEB Hollis Whiteman 9th Apr
Practice notes
IntroductionThe government’s strategy for tackling offshore tax evasion was initially set out in HMRC’s 2014 No Safe Havens and has been supplemented...
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Produced in partnership with Nicholas Griffin QC and Tom Broomfield of QEB Hollis Whiteman 9th Apr
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 9th Apr
Practice notes
This Practice Note is about the penalty regime in the Finance Act 2009 (FA 2009) for the late payment of:•income tax and Class 1 NICs via pay as you...
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Produced in partnership with Philip Rutherford 8th Apr
Practice notes
FORTHCOMING CHANGE: Finance Bill 2021 contains a number of measures, taking effect from Royal Assent, to take further action against those who...
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26th Mar

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