| 1 | Demergers: tax overview This note gives an overview of the reasons for, and the different types and tax implications of, demergers. | Practice note: overview | Maintained |
| 2 | Dividends: tax overview This note is an overview of the UK tax treatment of dividends. It also summarises the rules relating to shadow advance corporation tax, which govern the recovery of surplus advance corporation tax. | Practice note: overview | Maintained |
| 3 | Scrip dividends: tax overview This note summarises the UK tax treatment of scrip dividends issued by UK companies and dividend reinvestment plans (DRIPs) of UK companies. | Practice note: overview | Maintained |
| 4 | Substantial shareholding exemption: overview This note is an overview of the reliefs available and the main conditions that need to be satisfied under the substantial shareholding exemption provisions. | Practice note: overview | Maintained |
| 5 | 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 |
| 6 | 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 |
| 7 | Arrangements and reconstructions: comparison between ... A note outlining the changes to the law in relation to arrangements and reconstructions (including mergers and divisions of public companies) made by the Companies Act 2006 (2006 Act). For general background to the 2006 Act, see Practice note, Companies Act 2006: materials. Part 26 (arrangements and reconstructions) and Part 27 (mergers and divisions of public companies) came into force on 6 April 2008. | Practice notes | 06-Apr-2008 |
| 8 | Asset purchases: tax aspects of hive downs This practice note discusses the tax implications of a hive down. A hive down is the transfer of all or part of the business or assets of a company to a new company (the hive down company), followed by the sale of the shares in the hive down company to a third party. | Practice notes | Maintained |
| 9 | Capital reduction demergers: tax A practice note explaining the steps for carrying out a capital reduction demerger, the tax implications of structuring as a capital reduction demerger for the shareholders and group companies, tax clearances and the demerger agreement. | Practice notes | Maintained |
| 10 | Corporate insolvency and losses: tax This practice note deals with the issue of using and preserving the losses of an insolvent company, both generally and in the contexts of a hive down of its assets and business, and of group relief. | Practice notes | Maintained |
| 11 | Deal analysis: Demergers This document contains a table with details of significant 2006 and 2007 demergers by UK listed and AIM companies. The table briefly describes the structure used and links to the public documents, where available. For details of more recent demergers and for fuller details of the issues covered in the table below, see PLC What's Market. For more information on demergers, see PLC Practice note, Demergers. | Practice notes | 26-Nov-2008 |
| 12 | Demergers and schemes of reconstruction: stamp duty and ... A practice note on the stamp duty and stamp duty land tax (SDLT) aspects of demergers and schemes of reconstruction. | Practice notes | Maintained |
| 13 | Demergers and the substantial shareholding exemption A practice note discussing how the substantial shareholding exemption applies on a demerger. | Practice notes | Maintained |
| 14 | Direct dividend demergers: tax A practice note on the tax implications of direct dividend demergers. | Practice notes | Maintained |
| 15 | 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 |
| 16 | Dividends: tax A practice note on the tax treatment of dividends. | Practice notes | Maintained |
| 17 | Group reorganisations: tax This note gives an overview of the key tax issues that can arise when a group reorganisation takes place. | Practice notes | Maintained |
| 18 | Group restructurings in insolvency: tax issues A practice note about the tax implications of restructuring a group in an insolvency situation. The note covers the position of the group and its shareholders. | Practice notes | Maintained |
| 19 | Groups of companies: tax Tax legislation gives special tax treatment to certain transactions between group company members, such as group and consortium relief and relief for chargeable gains groups. This note considers that treatment. The stamp duty, stamp duty land tax and value added tax position of group companies is also considered. | Practice notes | Maintained |
| 20 | Income tax: anti-avoidance and secondary liability This note is a general summary of the anti-avoidance rules applying for the purposes of UK income tax and the situations in which one person may be liable for income tax primarily chargeable to another person. It also provides links to notes describing other aspects of the UK income tax rules, such as how income is taxed and exemptions from income tax. | Practice notes | Maintained |
| 21 | Income tax: calculation of income profits This note is a general summary of the rules for calculating income for the purposes of UK income tax. It also provides links to notes describing other aspects of the UK income tax rules, such as how income is taxed and exemptions from income tax. | Practice notes | Maintained |
| 22 | Income tax: exemptions and reliefs This note is a general summary of exemptions and relief from UK income tax. It also provides links to notes describing other aspects of the UK income tax rules, such as how income is calculated for income tax purposes and how income is taxed. | Practice notes | Maintained |
| 23 | Income tax: general principles This note is a general summary of the principles underpinning UK income tax. It describes what income is and how it is taxed. It also provides links to notes describing other aspects of the UK income tax rules, such as calculation of income and exemptions from income tax. | Practice notes | Maintained |
| 24 | Income tax: use of losses This note is a general summary of how losses may be used under the UK income tax rules. It also provides links to notes describing other aspects of the UK income tax rules, such as how income is taxed and exemptions from income tax. | Practice notes | Maintained |
| 25 | Key dates for corporate tax practitioners: 2012 A practice note listing key forthcoming dates in 2012 for corporate tax practitioners. | Practice notes | Maintained |
| 26 | Offshore holding companies This overview summarises the tax issues for a UK-based multinational wishing to move its tax residence from the UK, and explains how this can be achieved in practice. It covers reasons for corporate emigration, migrating an existing company, introducing a new holding company, post-implementation reorganisations and dividend access arrangements. | Practice notes | 23-Aug-2012 |
| 27 | Schemes of arrangement and demergers: tax A practice note on the tax implications of a demerger carried out as a scheme of arrangement made under Part 26 of the Companies Act 2006 (formerly section 425 of Companies Act 1985). (This note was formerly called "Section 425 Companies Act 1985 schemes: tax". It has been renamed to reflect the entry into force on 6 April 2008 of Part 26 of the Companies Act 2006, which replaces section 425 of the Companies Act 1985.) | Practice notes | Maintained |
| 28 | Schemes of reconstruction: tax A practice note on the tax reliefs applying to schemes of reconstruction. These reliefs are particularly relevant in demergers and other restructurings. | Practice notes | Maintained |
| 29 | Scrip dividends and dividend reinvestment plans: tax A practice note on the tax treatment of scrip dividends and dividend reinvestment plans (DRIPs). | Practice notes | Maintained |
| 30 | Section 110 Insolvency Act 1986 liquidation schemes: tax A practice note on the tax implications of a demerger carried out using a scheme made under section 110 of Insolvency Act 1986. | Practice notes | Maintained |
| 31 | Shadow ACT A practice note on shadow advance corporation tax (shadow ACT). | Practice notes | Maintained |
| 32 | Share issues: tax An issue of shares may be structured in a number of ways. This note outlines the different structures and then considers the main tax issues by reference to each of the relevant taxes: corporation tax, capital gains tax, income tax, value added tax, stamp duty and stamp duty reserve tax. | Practice notes | Maintained |
| 33 | 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 |
| 34 | Stamp duty This note considers the practical impact of stamp duty on commercial transactions. 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 |
| 35 | Stamp duty land tax This practice note considers the practical impact of stamp duty land tax in the context of commercial transactions. | Practice notes | Maintained |
| 36 | Stamp duty reserve tax This practice note considers the practical impact of stamp duty reserve tax in the context of commercial transactions. 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 |
| 37 | 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 |
| 38 | Statutory demergers: tax A practice note on the tax treatment of exempt distributions (direct and three-cornered distributions falling within sections 1073 to 1099 of the Corporation Tax Act 2010 (previously sections 213 to 218 of Income and Corporation Taxes Act 1988)), known as "statutory demergers". | Practice notes | Maintained |
| 39 | Substantial shareholding exemption A note on the substantial shareholding exemption which exempts companies from corporation tax on a gain made on the disposal of a substantial shareholding in another company. | Practice notes | Maintained |
| 40 | Tax clearances: demergers This practice note discusses the situations in which UK tax relief may be available for demergers and the procedure for obtaining HMRC clearance for such transactions. | Practice notes | Maintained |
| 41 | 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 |
| 42 | Tax clearances: transfer of trade This practice note discusses the situations in which UK tax relief may be available for the transfer of a trade and the procedure for obtaining HMRC clearance for such transactions. | Practice notes | Maintained |
| 43 | Tax legislation tracker: archive A document containing items formerly found in PLC Tax legislation trackers but that are now in force. | Practice notes | Maintained |
| 44 | Tax legislation tracker: corporate A document tracking the development of certain notable pieces of proposed new legislation relating to corporate taxation. | Practice notes | Maintained |
| 45 | 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 |
| 46 | Three-cornered demergers: tax A practice note on the tax implications of a three-cornered demerger. | Practice notes | Maintained |
| 47 | 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 |
| 48 | 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 |
| 49 | What's Market (UK): recent deals published A practice note listing the recent deals published on What's Market. | Practice notes | Maintained |