| 1 | A guide to PLC's FATCA resources A guide to PLC's resources on the US Foreign Account Tax Compliance Act (FATCA). | Practice note: overview | Maintained |
| 2 | SRA Code of Conduct 2011 toolkit A toolkit to guide users through PLC's resources on the SRA Code of Conduct 2011. | Practice note: overview | Maintained |
| 3 | Anti-avoidance case law and tax: Direct taxes and stamp ... This practice note summarises the development of anti-avoidance case law from WT Ramsay v Inland Revenue Commissioners (1982) 54 TC 101 to date. It also includes some practical tips for structuring transactions to reduce the risk of attack by HMRC based on anti-avoidance case law. | Practice notes | Maintained |
| 4 | Anti-avoidance case law and tax: VAT: abuse of rights This practice note summarises the development of anti-avoidance case law from the European Court of Justice's decision in Halifax to date. It also includes some practical tips for structuring transactions to reduce the risk of attack by HMRC based on anti-avoidance case law. | Practice notes | Maintained |
| 5 | Bank levy A practice note discussing the details of the bank levy applying from 1 January 2011. | Practice notes | Maintained |
| 6 | Debt restructuring: tax aspects A practice note about the tax implications of restructuring the debt of a company for the borrower, the lender and the guarantor. | Practice notes | Maintained |
| 7 | ECJ direct tax cases: where are they now? This practice note tracks cases of significance from a UK direct tax perspective that involve claims that direct tax law infringes the freedoms set out in the Treaty on the Functioning of the European Union (TFEU) (previously known as the EC Treaty). Links are provided to relevant judgments and PLC legal updates and articles. It also contains a summary of the key principles of EU law relevant to UK tax and a summary of the TFEU freedoms most often encountered in direct tax cases. | Practice notes | Maintained |
| 8 | Execution of deeds and documents Overview of the key legal requirements relating to the execution of deeds and documents under the laws of England and Wales. It reflects the law on execution from 1 October 2009. For details of the law governing execution of deeds and documents before 1 October 2009, see Practice note, Execution of deeds and documents: pre-1 October 2009. | Practice notes | Maintained |
| 9 | Foreign profits of companies: tax reform A practice note about measures to reform UK corporation tax in the following areas: Controlled foreign companies. Profits and losses of overseas branches. Intellectual property. Dividends received by companies. Interest paid by companies. International movement of capital (treasury consent). | Practice notes | Maintained |
| 10 | Funding the distressed company: tax issues A practice note about the tax implications of various methods of financing a company in financial difficulties. | Practice notes | Maintained |
| 11 | Governing law and jurisdiction clauses A practice note covering the reasons for including governing law and jurisdiction clauses with drafting guidance. | Practice notes | Maintained |
| 12 | Interest clauses A note giving guidance on a standard form boilerplate clause for interest on overdue payments under a contract. It includes guidance on when an interest clause may be unenforceable as a penalty clause, and on the effect of the Late Payment of Commercial Debts (Interest) Act 1998, as amended by the Late Payment of Commercial Debts Regulations 2013. | Practice notes | Maintained |
| 13 | Lending activities: tax This practice note discusses the tax issues that arise when lending and borrowing money, in particular, corporation tax and income tax issues (including withholding tax). | Practice notes | Maintained |
| 14 | Limits on tax deductions for interest: the debt cap A practice note setting out the rules imposing a limit on the corporation tax deductions that UK members and branches of a worldwide group are allowed for interest (known as the "debt cap"). The debt cap rules are contained in Part 7 of, and Part 7 of Schedule 9 to, the Taxation (International and Other Provisions) Act 2010 (TIOPA 2010) (formerly, section 35 of, and Schedule 15 to, the Finance Act 2009). | Practice notes | Maintained |
| 15 | Loan relationships This practice note covers, in detail, the tax rules applying to companies in connection with their loan relationships. | Practice notes | Maintained |
| 16 | Repos: tax This practice note analyses the UK tax treatment of sale and repurchase agreements (repos) for companies. | Practice notes | Maintained |
| 17 | Set-off clauses A note on boilerplate clauses that create or limit contracting parties' rights to set off monetary cross-claims against each other. It also outlines the following non-contractual rights of set-off: legal set-off, equitable set-off, banker's set-off and insolvency set-off. | Practice notes | Maintained |
| 18 | Stock lending: tax This practice note analyses the UK tax treatment of stock lending for companies. | Practice notes | Maintained |
| 19 | Syndication, secondary market trades and other transactions ... This practice note discusses the UK tax issues that may arise where a lender seeks to divest itself of, or spread, exposure under a loan by entering into syndication arrangements or other transactions. | Practice notes | Maintained |
| 20 | Tax for banking lawyers This practice note is a basic summary of the tax issues that frequently arise in respect of commercial lending transactions carried on by banks. Among other things, it considers distribution treatment for interest, withholding tax, stamp duty and VAT. | Practice notes | Maintained |
| 21 | Tax issues in loan agreements: negotiating guide This practice note examines the UK tax issues most commonly encountered in loan agreements (including facility agreements) and discusses how best to negotiate them if you are, or are advising, either the borrower or the lender. It discusses direct taxes, withholding tax, stamp taxes and VAT. | Practice notes | Maintained |
| 22 | Tax legislation tracker: archive A document containing items formerly found in PLC Tax legislation trackers but that are now in force. | Practice notes | Maintained |
| 23 | Tax legislation tracker: finance A document tracking the development of certain notable pieces of proposed new legislation relating to finance taxation. | Practice notes | Maintained |
| 24 | The UK as a holding company location: tax factors A discussion about the tax factors to consider when deciding whether to locate a holding company in the UK, including the territorial scope of UK tax, relief for financing expenses, shareholder tax issues, VAT, stamp duty, and anti-avoidance rules, such as transfer pricing. | Practice notes | Maintained |
| 25 | Thin capitalisation and transfer pricing A discussion of the UK's thin capitalisation and transfer pricing rules in the context of cross-border transactions. | Practice notes | Maintained |
| 26 | Transfer pricing This practice note discusses the UK transfer pricing rules as they apply to cross-border and domestic transactions. This note does not address how the transfer pricing rules impact on specific industries, such as insurance or energy/utility, where these industries deviate from the general rules. | Practice notes | Maintained |
| 27 | VAT issues for banks This practice notes summarises the various VAT issues that arise for banks in the course of their business. | Practice notes | Maintained |
| 28 | Withholding tax This practice note is a summary of the UK withholding tax rules on payments of interest and certain other payments (such as annual payments, guarantee payments, patent royalties and other royalties). It considers when withholding arises (including when interest has a UK source and when it is "yearly interest" rather than "short interest"). It also considers exemptions, such as the Quoted eurobond exemption and exemption under double tax treaties, and outlines the effect of the EU savings tax directive. Further, it discusses documenting for withholding tax, including gross-up clauses, and accounting for tax withheld. | Practice notes | Maintained |
| 29 | Withholding tax: bank deposits A short summary of how the withholding tax rules apply in relation to bank deposits when interest is paid or deposited by a "deposit-taker". | Practice notes | Maintained |