| 1 | A guide to Practical Law's FATCA resources A guide to Practical Law's resources on the US Foreign Account Tax Compliance Act (FATCA). | Practice note: overview | Maintained |
| 2 | Disguised remuneration tax legislation (rewards from third ... The Finance Act 2011 introduced anti-avoidance legislation (Part 7A of the Income Tax (Earnings and Pensions) Act 2003) to counter the use of employee benefit trusts and other intermediaries to reward employees (or their family members) in a way that avoids income tax or NICs. HMRC referred originally to these arrangements as disguised remuneration (and this phrase is now widely used, but it is not in the legislation). Part 7A applies from 6 April 2011 and has the potential to tax many arrangements in addition to the targeted avoidance schemes. This note provides an overview of Part 7A. | Practice note: overview | Maintained |
| 3 | Loan notes in share deals: tax FAQs Frequently asked tax questions relating to the use of loan notes as consideration for the sale of shares. | Practice note: overview | Maintained |
| 4 | Taper relief: overview This note is a brief overview of the key features of capital gains tax (CGT) taper relief as it applied to shares and securities. Taper relief was available to individuals, personal representatives and trustees.Taper relief has been abolished for disposals made on or after 6 April 2008 (see paragraphs 23 to 56 of Schedule 2 to the Finance Act 2008). Taper relief does not apply to deferred gains which come into charge after 5 April 2008. | Practice note: overview | 05-Apr-2008 |
| 5 | Tax clearances: general This note discusses the current UK rulings system and practical issues relating to clearances. It also links to several other practice notes that provide guidance on clearances in specific situations. | Practice note: overview | Maintained |
| 6 | 2007 Public M&A deals: the main features This table lists takeovers announced in 2007 with a value in excess of £250 million. The deals are organised by size, with the largest first. The table lists the main features of each deal and provides a link to the announcement of each deal. It also links through to wording from the offer documentation where appropriate, for example to the wording of bespoke conditions. We have prepared a more detailed summary for each completed deal which again users can click through to if they require further information on an individual deal. The detailed summaries for example include trigger events for break fees, more detail of pension deficit negotiations and so on.We have highlighted in this overview:deal structure;any restriction on the target's right to agree a break fee with another bidder;if the target gave the bidder a right to match any competing bid for a set period;unusual or bespoke conditions;extended disclosures regarding the target's workforce;deals involving negotiations with the target's pension trustees.More details can then be found by clicking through to the deal announcement or to the deal summary. For details of more recent public takeovers and for fuller details of the issues covered in the table below, see PLC What's Market. | Practice notes | 31-Dec-2007 |
| 7 | 2008 Public M&A deals: the main features This table contains details of takeovers announced in 2008 with a value in excess of £250 million. The table includes links to the offer documentation where this was made available on one of the company's websites. For details of more recent public takeovers and for fuller details of the issues covered in the table below, see PLC What's Market. | Practice notes | 26-Nov-2008 |
| 8 | Deal analysis: analysis of schemes of arrangement used to ... A table setting out the key features of schemes of arrangement used to effect the largest recent takeovers of UK public companies, between 1 September 2006 and 31 May 2008. For details of more recent schemes of arrangement and for fuller details of the issues covered in the table below, see PLC What's Market. Schemes have been the structure of choice for most of the largest deals announced in 2007 and 2008. Of the deals with a value of £250 million and above announced in 2007, 28 were announced or subsequently structured as schemes and 6 were offers. For 2008 (up to November) these figures were 14 and 8 respectively. The table sets out: Details of any right reserved by the parties to convert the structure to an offer. A further example of a transaction structured as a scheme being switched to an offer was the Wienerberger acquisition of Baggeridge Brick when a potential rival bidder acquired a 17% stake. Wienerberger later increased its offer price, acquired a substantial stake and declared its offer unconditional as to acceptances. Note that the Takeover Code now deals specifically with switching from a scheme to an offer and vice versa - see Section 8 of Appendix 7 to the Code.An overview of the structure of the scheme.Details of the obligations to implement the scheme and any subsequent timetable disruptions.For further information on the use of a scheme of arrangement to implement a takeover offer see PLC Practice note, Schemes of arrangement: takeovers , PL | Practice notes | 31-May-2008 |
| 9 | Deal analysis: loan note alternatives on public takeovers Table setting out the key features of the loan note alternatives offered on takeovers between 1 October 2006 and 28 February 2008 with a value in excess of £250 million. For details of more recent loan note alternatives on public takeovers and for fuller details of the issues covered in the table below, see PLC What's Market. The table sets out: Details of any guarantee.Whether there was a condition as to a minimum take up level for the loan note alternative before the bidder would issue any loan notes.Whether the loan notes were available for the entire cash amount of the offer or only part of it.Redemption details.The interest rates on the loan notes.Transfer restrictions.For further information on loan note alternatives to takeover offers see PLC Practice note, Consideration and underwriting: takeovers and PLC What's Market. | Practice notes | 28-Feb-2008 |
| 10 | Direct taxes This practice note gives an overview of direct taxes in the UK tax regime. It covers income tax, corporation tax and capital gains tax. It discusses the principles of calculation, rates, payment and compliance, and reliefs (such as capital allowances and research and development (R&D) relief). | Practice notes | Maintained |
| 11 | Key dates for corporate tax practitioners: 2012 A practice note listing key forthcoming dates in 2012 for corporate tax practitioners. | Practice notes | Maintained |
| 12 | Key dates for corporate tax practitioners: 2013 A practice note listing key forthcoming dates in 2013 for corporate tax practitioners. | Practice notes | Maintained |
| 13 | Share sales: pre 6 April 2008 CGT position and planning This practice note sets out the tax treatment of disposals of shares by individuals before 6 April 2008 and outlines some of the tax planning which took place before changes to the capital gains tax rules took effect on 6 April 2008. It also covers loan notes and earn-outs issued before 6 April 2008 in consideration for the sale of shares. We have retained this material as it may be useful when completing tax returns for periods to 5 April 2008 and dealing with HMRC enquiries relating to those periods. | Practice notes | 05-Apr-2008 |
| 14 | Stamp duty This note considers the practical impact of stamp duty on commercial transactions. | Practice notes | Maintained |
| 15 | Stamp duty reserve tax This practice note considers the practical impact of stamp duty reserve tax in the context of commercial transactions. | Practice notes | Maintained |
| 16 | Stamp duty: reliefs This note considers the various reliefs and exemptions from stamp duty available in a commercial context. NOTE: This resource is being reviewed in light of the 2013 Budget. For more information, see Legal update, 2013 Budget: key business tax announcements. | Practice notes | Maintained |
| 17 | Tax clearances: exchanges of securities and reconstructions This note describes the UK tax treatment of reconstructions and exchanges of securities, and discusses the procedure for obtaining HMRC clearance for such transactions. | Practice notes | Maintained |
| 18 | Tax legislation tracker: archive A document containing items formerly found in PLC Tax legislation trackers but that are now in force. | Practice notes | Maintained |
| 19 | Tax legislation tracker: corporate A document tracking the development of certain notable pieces of proposed new legislation relating to corporate taxation. | Practice notes | Maintained |
| 20 | Tax on chargeable gains: general principles This note is a general summary of the UK rules applying to the taxation of chargeable gains. It describes what chargeable gains are, what assets are affected, when disposals arise, the way in which gains are calculated and the manner in which they are taxed, exceptions from taxation, anti-avoidance rules and how allowable losses may be used. This note is intended as a general overview, so you should be aware that the tax treatment in a particular case may differ from the general position described in this note. | Practice notes | Maintained |
| 21 | Transactions in securities: tax anti-avoidance This practice note explains the transactions in securities rules under which HMRC can counteract a tax advantage for a taxpayer arising from certain types of transaction(s) in shares or securities. | Practice notes | Maintained |
| 22 | What's Market (UK): recent deals published A practice note listing the recent deals published on What's Market. | Practice notes | Maintained |