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.
The Supreme Court has unanimously dismissed the appeal, holding that a court should exercise its discretion under CPR 19.23(1)(a) to disapply a group...
Tax analysis: In Scott Knight v HMRC, the First-tier Tax Tribunal (FTT) declined HMRC’s application to strike out the taxpayer’s appeal against a...
Pensions analysis: The Pension Protection Fund Ombudsman has rejected a complaint about an incorrect member communication. Martin Scott of gunnercooke...
This week's edition of Tax weekly highlights includes: (1) the Taxation (Energy and Vehicles) Act receiving Royal Assent, (2) HMRC’s consultation on...
Tax analysis: In Elborne and others v HMRC, the Court of Appeal held that a 2003 inheritance tax (IHT) home loan scheme succeeded because the...
This Practice Note tracks the progress of secondary legislation introduced as part of the government’s post-Brexit reform agenda. It includes a...
ARCHIVED: This Practice Note has been archived and is not maintained. It tracks the progress of UK primary legislation introduced as part of the...
ARCHIVED: This Practice Note has been archived and is not maintained.On 23 June 2016, the UK held a referendum on its membership of the EU, with a...
The UK’s formal withdrawal from the EU took effect at 11 pm on 31 January 2020 (exit day). At this point, the withdrawal period under Article 50 TEU...
This Practice Note provides an overview of retained EU law as it applied from 2021–23, including the key definitions and concepts with reference to...
ARCHIVED: This Precedent has been archived and is not maintained.These training materials consist of template PowerPoint slides that can be used as...
FORTHCOMING CHANGE relating to the modernisation of stamp taxes on shares framework: Stamp duty and SDRT will, in 2027, be replaced with a single,...
FORTHCOMING CHANGE relating to the modernisation of stamp taxes on shares framework: Stamp duty and SDRT will, in 2027, be replaced with a single,...
FORTHCOMING CHANGE: Following a call for evidence in 2020, the resulting outcome published in 2021, consideration by the relevant HMRC and industry...
Transfer of a going concern1The Seller and the Buyer intend that the sale and transfer of the Property in accordance with the terms of this Agreement...
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),...
A clawback provision (usually seen where a fund uses a deal-by deal model) that ensures that the carried interest partner does not receive more than its agreed percentage of carried interest over the life of the fund. So, for example, if it receives 21% of the partnership’s profits instead of the agreed 20%, limited partners can claw back the extra 1%.
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 aggregate of income and chargeable capital gains of a company.