Kevin Ashman and Tom Eyre-Brook (Hogan Lovells) set out the tax considerations for non-UK resident individuals seeking to invest in UK property, complete with a case study
Following the BAA case, HMRC has shifted its position on the recovery of deal fees. In this practice guide, Alan Sinyor (Berwin Leighton Paisner) outlines the key principles of the approach which should now be considered.
Michael Thomas (Gray’s Inn Tax Chambers) reviews the lessons from recent case law.
Secondary liabilities can present a significant concealed tax risk for a purchaser when acquiring a UK corporate target. Due to the wide reach of the provisions, a diligence review of target entities alone will often not identify all the potential tax risks. Mark Boyle and Joe Grehan (EY) provide this practice guide on steps to take to mitigate these risks
Toby Price and Martin Walker (Deloitte) consider the potential stamp tax traps arising on IPOs, including pre-IPO reorganisations and overallotment (or greenshoe) options, as well as offering practical solutions
FATCA affects the operations of most UK funds. Andrey Krahmal provides a summary
Emma Hardwick considers the point during sale negotiations at which a target may lose the ability to surrender or receive group relief
For any transaction involving bonds or notes, there are a number of potential difficulties that may arise, which may include issues involving stamp taxes, VAT, withholding tax, FATCA, and the tax treatment of the bond issuer and bondholders. Eloise Walker and Abigail McGregor provide a handy practice guide for advisers
Natasha Kaye and Jacob Gilkes consider the EIS and stamp duty provisions which apply when introducing a new holding company
There are viable alternatives to EMI if a company does not qualify or an individual employee does not meet the criteria to participate. Thomas Dalby sets out the key considerations for advisers.