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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
VAT penaltiesIP COMPLETION DAY: The Brexit transition period ended at 11pm on 31 December 2020. At this time (referred to in UK law as ‘IP completion...
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15th Aug
Practice notes
Share for share exchanges and schemes of reconstruction—anti-avoidance rulesThis Practice Note is about the tax anti-avoidance rules that apply to a...
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15th Aug
Practice notes
Real estate—anti-avoidance: disposals of land and taxing capital gains as income (pre 5 July 2016) [Archived]ARCHIVED: This Practice Note has been...
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Produced in partnership with Charles Goddard of Rosetta Tax 15th Aug
Practice notes
Penalties for inaccuracies in returns—introduction to the regimeFORTHCOMING CHANGE relating to inaccuracy penalties: Following an initial discussion...
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Produced in partnership with Philip Rutherford 15th Aug
Practice notes
Penalty reductions for inaccuracies—disclosure and special circumstancesFORTHCOMING CHANGE relating to inaccuracy penalties: Following an initial...
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Produced in partnership with Philip Rutherford 15th Aug
Practice notes
Duties of a senior accounting officer (SAO)Coronavirus (COVID-19) impact on SAO rules: Because of the effect of coronavirus on businesses, the filing...
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15th Aug
Practice notes
Penalties for inaccuracies in returns—reasonable careFORTHCOMING CHANGE relating to inaccuracy penalties: Following an initial discussion document...
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15th Aug
Precedents
Clearance letter—statutory demerger[Team Leader][insert HMRC address][insert date]Application for clearance[s] in advance under section 1091 of the...
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Produced in partnership with Robert Langston of Saffery Champness 15th Aug
Precedents
Pro forma index to authorities bundle for a tax tribunal caseTC/[insert year]/[insert case number]In the first tier tribunal(Tax chamber)Between:[Name...
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15th Aug
Precedents
Clearance letter—TCGA 1992, ss 138 and 139(5), ITA 2007, s 701 and CTA 2010, s 748[Team Leader][insert HMRC address][insert date]Application for...
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15th Aug
Precedents
Pro forma index to documents bundle for a tax tribunal caseTC/[insert year]/[insert case number]In the first tier tribunal(Tax chamber)Between:[Name...
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15th Aug
Precedents
Advance assurance accompanying letter—SEISIP COMPLETION DAY: The Brexit transition period ended at 11pm on 31 December 2020. At this time (referred to...
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15th Aug
Precedents
Advance assurance accompanying letter—EISSmall Company Enterprise Team(Admin team) Mid-size Business S07777NewcastleNE98 1ZZ[Insert date][Commercially...
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15th Aug
Precedents
Qualifying holding advance assurance letter—VCTSmall Companies Enterprise Centre (Admin team)Mid-size Business S0777NewcastleNE98 1ZZ[Insert...
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15th Aug
Precedents
Clearance letter—non—statutory clearanceHM Revenue & Customs[insert appropriate team- this is usually the HMRC Non-Statutory Clearance Team...
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15th Aug
Precedents
Anti-tax evasion facilitation clause—pro-customer1Anti-tax evasion facilitation1.1For the purposes of this clause 1:1.1.1the expressions ‘Associated...
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15th Aug
Practice notes
Failure to prevent facilitation of tax evasion—compliance issuesThe Criminal Finances Act 2017 (CFA 2017) introduced a corporate offence of failure to...
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15th 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 12th Aug
Practice notes
Civil tax fraud investigations—Code of Practice 9Civil investigation of tax fraudHMRC’s published policy in respect of tax fraud states that HMRC will...
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Produced in partnership with Corker Binning 11th Aug
Practice notes
Cheating the public revenueOffence of cheating the public revenueThe offence of cheating the public revenue is a common law offence triable only on...
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11th Aug

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