Content written by the author of the leading textbook in this area and includes several sector specific Practice Notes. It links directly to Tolley’s Orange Tax Handbook, Tax Journal and key text De Voil.
Excellent practical content for loans, derivatives and debt capital markets. The content links directly to Tolley’s Yellow Tax Handbook, Simon’s Taxes, Tolley annuals, Tax Journal and key text Ghosh Johnson and Miller.
This is an area where many people find themselves a bit at sea. Our content is practical, detailed and covers the major issues in dealing with a tax enquiry or dispute.
When you need to delve deeper, Lexis+® Tax links you to trusted tax texts, including Tolley’s Yellow and Orange Tax Handbooks, Simon’s Taxes, Sergeant and Sims, De Voil, Tax Journal and Taxation.
This week's edition of Tax weekly highlights includes: (1) updated HMRC guidance on correcting transfer pricing errors, (2) updated HMRC guidance on...
Private Client analysis: From April 2027 some pension death benefits will be within scope of inheritance tax (IHT). New Regulations were published on...
Tax analysis: In Oakwood Great Oak Ltd v HMRC, the First-tier Tax Tribunal (FTT) allowed the taxpayer’s appeal in relation to whether a property...
Pensions analysis: In Reed v Revenue and Customs Commissioners, the First-tier Tribunal upheld an unauthorised payments charge arising from a pension...
This week's edition of Tax weekly highlights includes: (1) News Analysis on FTT’s decision in Property 118, (2) News Analysis on UT’s decision in Gary...
The concept of a ‘permanent establishment’ (PE) is set out in Article 5 of the Organisation for Economic Co-operation and Development (OECD) model tax...
FORTHCOMING CHANGE relating to updating definitions for the bank levy legislation: On 16 July 2026, HMRC published draft regulations that would update...
Migration refers to the transfer by a company of its tax residence from one jurisdiction to another. This may be done for a number of reasons....
FORTHCOMING CHANGE relating to profits from exploration and exploitation rights: On 13 July 2026, HMRC published for consultation draft legislation...
This Practice Note looks at the meaning of a permanent establishment (PE) for tax purposes, both under UK domestic law and in double tax treaties...
[send by email to the address shown in HMRC manual CTM34195][Date]Dear [insert organisation name]Notification of intention to migrate — [Company name,...
HM Revenue and Customs[insert address][insert date]Election under section 171A(4) of the Taxation of Chargeable Gains Act 1992This election is made...
FORTHCOMING CHANGE: At Tax Update 2026, HMRC published a consultation on ‘Modernising the distributions framework’. As part of the package of...
This Agreement is made on [insert date]Parties1[Insert Employer’s name] whose registered office is at [insert Employer’s address], company...
This [Deed OR Agreement] dated [•] 20[•] is madeParties1[insert name], a company incorporated in England and Wales with registered number [insert...
VAT treatment of damages and compensation paymentsA damages or compensation payment may attract VAT. This depends on exactly what the payment is for....
The double taxation treaty passport scheme (DTTP scheme)The double taxation treaty passport scheme (DTTP scheme) enables a borrower to apply for and...
What are capital allowances and capital expenditure?What are capital allowances?Capital allowances are the means by which tax relief is given for some...
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...
Residential service charges—VAT implicationsThis Practice Note is about the VAT treatment of residential service charges.Service charges payable to...
Commercial service charges—VAT implicationsThis Practice Note is about the VAT treatment of non-residential service charges. General positionService...
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...
Qualifying charitable donations and excess management expensesAll companies within the charge to corporation tax can deduct qualifying charitable...
Amortisation of intangible fixed assetsWhere a company acquires (or otherwise incurs capitalised expenditure upon) an intangible fixed asset that...
The Budget and Finance Bill processThe Budget is a Parliamentary event at which the Chancellor of the Exchequer makes important announcements relating...
Tax treatment of reorganisations of share capitalThis Practice Note is about the meaning of a reorganisation for tax purposes, and the tax treatment...
Capital gains—intra-group asset transfersCompanies which form a group for capital gains purposes are able to transfer assets to one another free of...
VAT treatment of intermediaries, agents and disbursementsFor VAT purposes, an intermediary is a person who makes arrangements for, or facilitates, a...
How are investors in a private equity fund taxed on their share of the profits?This Practice Note sets out how the investors in a typical UK private...
Taxation of offshore funds—what is an offshore fund?Background to the offshore funds rulesSpecific tax legislation dealing with offshore funds was...
Partnerships and capital gainsThis Practice Note is about the capital gains tax and corporation tax on chargeable gains treatment of UK general...
Tax considerations on a loan agreement—the tax gross up clauseIt is standard market practice for loan agreements (also known as facility agreements),...
Generally, for the purposes of the Corporation Tax Acts 2010 (CTA 2010) a company has a permanent establishment in a territory if, and only if, (1) it has a fixed place of business there through which the business of the company is wholly or partly carried on, or (2) an agent acting on behalf of the company has and habitually exercises there authority to do business on behalf of the company (CTA 2010, s 1141).
The Value Added Tax Act 1994, s.5(2)(a) provides that supply "includes all forms of supply".
Supplies (but not acquisitions or importations) are said to be zero-rated if they are relieved by legislation from a charge to tax.