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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

Practice notes
Privilege in tax casesThis Practice Note has been written by Anne Redston, Barrister. It is her personal view; she is not authorised to speak for the...
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Produced in partnership with Anne Redston 15th Aug
Practice notes
Overpaid tax—the statutory regimesThis Practice Note outlines the statutory provisions regulating the recovery of:•overpaid direct tax, for instance...
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Produced in partnership with Etienne Wong of Old Square Tax Chambers 15th Aug
Practice notes
Penalties for inaccuracies in returns under old rules [Archived]ARCHIVED: This Practice Note has been archived and is not maintained. HMRC has the...
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Produced in partnership with Philip Rutherford 15th Aug
Practice notes
UK country-by-country reportingWhat is country-by-country reporting?Country-by-country (CbC) reporting essentially requires large multinationals to...
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15th Aug
Practice notes
Calculating the penalty for inaccuracies—behaviour of the taxpayerFORTHCOMING CHANGE relating to inaccuracy penalties: Following an initial discussion...
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15th Aug
Practice notes
Overpaid tax—restitutionThis Practice Note looks at the position where a person has overpaid tax (ie paid an amount by way of tax where tax was not...
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Produced in partnership with Etienne Wong of Old Square Tax Chambers 15th Aug
Practice notes
Direct tax treatment of damages and compensation paymentsWhere a dispute is brought to an end by a payment of damages or compensation, whether under a...
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15th Aug
Practice notes
EIS—process for seeking advance assurance and claiming reliefThe EIS is designed to encourage investment in smaller, higher-risk trading companies by...
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15th Aug
Practice notes
Statutory clearancesVarious tax provisions include a procedure under which a taxpayer can apply for a clearance from HM Revenue & Customs (HMRC) in...
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15th Aug
Practice notes
Penalty reductions for failure to notify a liability to taxFORTHCOMING CHANGE: HMRC has consulted on proposals to amend the rules in Schedule 41 to...
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Produced in partnership with Philip Rutherford 15th Aug
Practice notes
Introduction to senior accounting officer (SAO) requirementsCoronavirus (COVID-19) impact on SAO rules: Because of the effect of coronavirus on...
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15th Aug
Practice notes
Penalties for inaccuracies—partnerships and officers of a companyFORTHCOMING CHANGE relating to inaccuracy penalties: Following an initial discussion...
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Produced in partnership with Philip Rutherford 15th Aug
Practice notes
Scotland: devolved taxes and the Scottish tribunal systemThis Practice Note provides an introduction to the Scottish tax tribunal system, which deals...
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Produced in partnership with Kenneth Campbell QC of Sheriff Court Bench of Scotland 15th Aug
Practice notes
Tax alternative dispute resolution (ADR) procedureThis 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 15th Aug
Practice notes
Calculating the penalty for inaccuracies—potential lost revenueFORTHCOMING CHANGE relating to inaccuracy penalties: Following an initial discussion...
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Produced in partnership with Philip Rutherford 15th Aug
Practice notes
Statutory demergers—chargeable payments, clearance in advance and returnsThis Practice Note is about the following aspects of the tax rules on...
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15th Aug
Practice notes
Penalties for breaches of the senior accounting officer (SAO) rulesCoronavirus (COVID-19) impact on SAO rules: Because of the effect of coronavirus on...
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15th Aug
Practice notes
Suspended penalties for inaccuracies in returnsFORTHCOMING CHANGE relating to inaccuracy penalties: Following an initial discussion document that was...
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Produced in partnership with Philip Rutherford 15th Aug
Practice notes
Appealing a Revenue Scotland decisionCoronavirus (COVID-19) impact on tribunals: For information on the coronavirus implications for appeals to, and...
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Produced in partnership with Kenneth Campbell QC of Sheriff Court Bench of Scotland 15th Aug
Practice notes
Confidentiality and privacy in tax casesThis 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 15th Aug

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