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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
Tax considerations on a loan agreement—the tax gross up clauseIP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit...
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Produced in partnership with Eloise Walker of Pinsent Masons 19th May
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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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
Section 198 and 199 elections on transactions involving real estateThis Practice Note describes the law and practice relating to elections under...
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Produced in partnership with Martin Wilson 19th May
Practice notes
Loan capital exemption from stamp dutyDebt which:•qualifies as loan capital (whether it is short or long-term debt), and•satisfies further conditions...
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19th May
Practice notes
The Budget and Finance Bill processThe Budget is a Parliamentary event at which the Chancellor of the Exchequer makes important announcements relating...
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19th May
Practice notes
Capital reduction demergersThe reasons why a company might carry out a demerger, and the different ways in which a demerger may be structured, are...
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Produced in partnership with Zoe Feller of Bird & Bird 19th May
Q&As
Corporate redomiciliation—can a non-UK company redomicile into the UK?It is possible for a non-UK incorporated company to redomicile to the UK....
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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
Practice notes
Transfer of a trade under common ownershipSometimes the restructuring of a business will involve a company transferring an existing trade to a...
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19th May
Practice notes
SDLT group reliefFORTHCOMING CHANGE relating to FA 2008, Sch 36: In its Tax Information and Impact Note (TIIN) on freeports, the government announced...
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19th May

Most recent Taxes management and litigation content

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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16th Sep
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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16th Sep
Practice notes
Coronavirus (COVID-19) and tax—impact on tax appeals and tax tribunalsAppeals and applications to the First-tier Tribunal and Upper Tribunal are both...
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16th Sep
Practice notes
Judicial review in tax cases at the High CourtThis Practice Note has been written by Anne Redston, Barrister. It is her personal view; she is not...
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Produced in partnership with Anne Redston 16th Sep
Practice notes
Appealing an HMRC decisionCoronavirus (COVID-19) impact on tribunals: For information on the coronavirus implications for appeals to, and hearings at,...
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Produced in partnership with Anne Redston 16th Sep
Practice notes
Preparing for a tax tribunal caseThis Practice Note has been written by Anne Redston, Barrister. It is her personal view; she is not authorised to...
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Produced in partnership with Anne Redston 16th Sep
Practice notes
Coronavirus (COVID-19)—impact on annual accounts and reportsBackgroundThis Practice Note considers the impact that the coronavirus (COVID-19) pandemic...
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14th Sep
Practice notes
Appealing beyond the First-tier Tax TribunalFORTHCOMING CHANGE: The Ministry of Justice has consulted on proposals to amend arrangements for obtaining...
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Produced in partnership with Anne Redston 14th Sep
Practice notes
HMRC compliance checks, enquiries and discovery assessmentsThere are various options open to HMRC when it suspects that tax has not been paid, or has...
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13th Sep
Practice notes
Overpaid tax—interest and damagesThis Practice Note is about:•a taxpayer’s right to receive interest on repayments of overpaid tax, whether under a...
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Produced in partnership with Etienne Wong of Old Square Tax Chambers 9th Sep
Practice notes
Failure to prevent the criminal facilitation of tax evasion—the offencesThis Practice Note discusses the two ‘failure to prevent’ corporate criminal...
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Produced in partnership with Rhys Meggy of QEB Hollis Whiteman 7th Sep
Practice notes
Enablers of offshore tax evasion—civil sanctionsIntroductionThe government’s strategy for tackling offshore tax evasion was initially set out in...
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Produced in partnership with Nicholas Griffin QC and Tom Broomfield of QEB Hollis Whiteman 6th Sep
Practice notes
Offshore tax evaders—criminal offencesBackground to the strict liability offences for offshore tax evadersThe government’s strategy for tackling...
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Produced in partnership with Nicholas Griffin QC and Tom Broomfield of QEB Hollis Whiteman 6th Sep
Practice notes
Criminal Finances Act 2017—progress through Parliament [Archived]ARCHIVED: This archived Practice Note is not being maintained. It tracked the passage...
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6th Sep
Q&As
What is the amount of penalty for late payment of a scheme sanction charge assessment, with statutory authorities?Under section 239 of the Finance Act...
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6th Sep
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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6th Sep
Practice notes
Late payment penalties—PAYE, NICs and construction industry schemeThis Practice Note is about the penalty regime in the Finance Act 2009 (FA 2009) for...
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Produced in partnership with Philip Rutherford 6th Sep
Practice notes
Direct recovery of tax debts (DRD)Direct recovery of tax debts (DRD) refers to HMRC's ability to instruct banks and building societies (ie...
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6th Sep
Practice notes
What happens at a tax tribunal hearing?This Practice Note has been written by Anne Redston, Barrister. It is her personal view; she is not authorised...
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Produced in partnership with Anne Redston 6th Sep
Practice notes
Interest on late paid taxCoronavirus (COVID-19): During the coronavirus pandemic, HMRC allowed deferral of certain VAT payments and self-assessment...
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6th Sep

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