Taxation of Company Reorganisations


Book Description

Taxation of Company Reorganisations, Sixth Edition is an essential reference source for tax advisers which covers the basic rules of corporation tax and capital gains, reorganisations, share exchanges and other deemed reorganisations, reconstructions, mergers, demergers and branch incorporations, as well as cross-border transactions. Written by authors with more than fifty years' experience of dealing with clients from small owner-managed businesses to multinational corporate groups, this title includes guidance on the full range of corporate transactions and is applicable to a wide number of organisations. While there is comprehensive coverage of the technical and theoretical meaning of the legislation, the authors have also drawn on their vast practical experience, derived from many years of transaction-based work. This Sixth Edition has been brought fully up to date with recent Finance Acts including FA 2019 and the proposals for FA 2020 that were published in July 2019. It has been reviewed for company and European law and has been updated in relation to the following: - Changes to substantial shareholding exemptions in Finance (No. 2) Act 2017 - Changes to EIS, SEIS and VCT investment schemes in FA 2018 - The introduction of LBTT in Scotland and LTT in Wales - Stamp duty changes proposed for FA 2020 - Enhanced material on the taxation of goodwill and loan relationships on a reorganisation Cases updated since the last edition include: - Gallaher Ltd v Revenue and Customs Commissioners [2019] UKFTT 207 (TC) (on application of s171 TCGA 1992) - Hancock [2019] 1 WLR 3409 (Supreme Court decision) - Trigg [2018] EWCA Civ 17 (Court of Appeal decision)




Advanced Topics in Revenue Law


Book Description

The last several years have seen fundamental changes to the UK tax system. Nearly the entirety of the UK corporation tax and international tax rules have been rewritten by three new statutes – the Corporation Tax Acts 2009 and 2010 and the Taxation (International and Other Provisions) Act 2010. The UK has also implemented major new policies affecting the taxation of pensions, charities, savings vehicles, 'non-doms' and the foreign profits of UK companies. In addition, European Union law, and especially the case law of the Court of Justice of the European Union, has had an increasingly important impact on UK corporation tax and international tax law in particular. This new book on advanced topics in UK tax law is derived from material previously found in John Tiley's major text on Revenue Law that has been expanded and comprehensively updated to take account of these developments. The book deals with Corporation Tax, International and European Tax, Savings and Charities, in a manageable and portable volume for law students and practitioners. It complements the material on UK Income Tax, Capital Gains Tax, and Inheritance Tax found in Revenue Law, 7th edition. Unlike other tax law books, this text explains the new rules found in CTA 2009, CTA 2010 and TIOPA 2010 in light of its legislative predecessors. The book contains extensive references to the new legislation and also to the former enactments in ICTA 1988 and elsewhere. Those familiar with the old law but wanting to find their way round the new will find this work particularly valuable. The book is designed for law students taking advanced tax courses in the final year of their law degree course and for graduate students, but is intended to be of interest to all who enjoy tax law. Its purpose is not only to provide an account of the rules but to include citation of the relevant literature from legal periodicals and some discussion of or reference to the background material in terms of policy, history or other countries' tax systems.




Tolley's Guide to Employee Share Schemes


Book Description

With this new edition of Tolley's Guide to Employee Share Schemes you can be sure you're giving the best, up-to-date guidance on implementing employee share schemes which will save money for your client.The new edition of this title evaluates the range of employee share schemes available, looking at their processes, the statutory and regulatory requirements, HMRC's interpretation of share scheme issues and most importantly the tax benefits associated with the various schemes. You can rely on the detailed and expert guidance contained in this title to ensure you choose the most effective and tax efficient employee share scheme. This indispensable guide is written in a clear, practical style and includes worked examples and case studies throughout.




Principles of International Taxation


Book Description

The book provides a clear introduction to international taxation and presents its material in a global context, explaining policy, legal issues and planning points central to taxation issues, primarily from the viewpoint of a multinational group of companies. It uses examples and diagrams throughout to aid the reader's understanding and offers more in-depth material on many important areas of the subject. Traditionally published every 2 years in both print and digital formats, this content is a core requirement for student reading lists at both undergraduate and post graduate level. Fully updated to cover all new tax legislation and developments in light of the OECD BEPS project implementation, key areas to be included in this new edition are: - changes proposed by BEPS 2.0 in relation to taxation and the digital economy, including Pillar Two and the proposed new UN Model Article 12B; - further progress on the implantation of OECD Base Erosion and Profit Shifting implementation, including: -- an update on the implementation of BEPS recommendations including artificial avoidance of permanent establishment status and prevention of treaty abuse; -- the implementation of transfer pricing documentation and country-by-country reporting; -- multilateral instrument implementation; - the impact of Covid-19 on international taxation; - further developments in European direct taxation including the transparency package, directives on anti-tax avoidance and the common corporate tax base and state aid cases (Apple in particular) and updates to the Directive on Administrative Cooperation, and the new communication on Business Taxation for the 21st Century. - Proposals in relation to the taxation of digital business, in particular the OECD's unified approach and the UN modifications to the Model Double Taxation Convention. - Proposals for a global minimum corporate tax rate to curb base erosion and tax competition.




Pre-budget Report 2008


Book Description

The 2008 Pre-Budget Report presents updated assessments and forecasts of the economy and public finances, and reports on how in the face of major global economic shocks the Government intends to support the economy, businesses and households through these uncertain times while delivering its long-term goals. Measures announced include: temporarily reducing the Value Added Tax (VAT) rate to 15 per cent from1 December 2008 to 31 December 2009; bringing forward £3 billion of capital spending from 2010-11 including introducing a green stimulus supporting low carbon growth and jobs; introducing a new additional higher rate of income tax of 45 per cent for those with incomes above £150,000 from April 2011; increasing national insurance contributions by 0.5 per cent from April 2011; increasing alcohol and tobacco duties; a two pence per litre increase in fuel duty from 1 December). Immediate action to help those individuals and businesses most affected by the economic downturn include: increases in the income tax personal allowance; bringing forward the increase in Child Benefit; increases of the Child Tax Credit and a payment of £60 to all pensioners; help through mortgage rescue and Support for Mortgage Interest schemes for eligible homeowners in difficulty and a commitment from major mortgage lenders not to initiate repossession action within at least three months of an owner-occupier going into arrears; an additional £1.3 billion to support for the unemployed to find a new job; measures to help small and medium-sized enterprises facing credit constraints; a new HMRC Business Payment Support Service to allow businesses in temporary financial difficulty to pay their HMRC tax bills on a timetable they can afford; and more generous tax relief for businesses now making losses and the modification of a number of planned tax reforms, including vehicle excise duty, air passenger duty, and the deferral of the increase in the small companies' rate of corporation tax.




Tiley’s Revenue Law


Book Description

This is the ninth edition of John Tiley's major text on revenue law, covering the UK tax system, income tax, capital gains tax and inheritance tax, as well as incorporating sections dealing with corporation tax, international and European tax, savings and charities. This new edition is fully revised and updated with the latest case law, statutory and other developments, including Finance Act 2019. The book is designed for law students taking the subject in the final year of their law degree, or for more advanced courses, and is intended to be of interest to all who enjoy tax law. Its purpose is not only to provide an account of the rules but also to include citation of the relevant literature from legal periodicals and some discussion of, or reference to, the background material in terms of policy, history or other countries' tax systems. Copy the URL below to read a 2021 supplement highlighting new developments since the book's publication in 2019: https://www.bloomsbury.com/media/2v1ej5vw/tileys-revenue-law-supplement-2021.pdf




United States Code


Book Description










Revenue Law


Book Description

This is the 7th Edition of John Tiley's major text on revenue law, now massively restructured to focus upon the UK Tax system, Income Tax, Capital Gains Tax, and Inheritance Tax. What were previously sections dealing with Corporation Tax, International and European Tax, Savings and Charities have been spun-off to an entirely new book entitled Advanced Topics in Revenue Law. While this narrowing of the scope of Revenue Law means that it focuses on the most important UK taxes, its reduced size also makes it a more manageable and portable volume for law students and practitioners. As with previous editions, the text has been revised to incorporate changes wrought by new enactments in the past four years. This, however, remains the only book on tax law which continues to explain the new law found in ITEPA, ITTOIA and ITA in light of its legislative predecessors, with references to the former enactments still remaining where relevant. Those familiar with the old law of income tax but wanting to find their way round the new will find this work particularly valuable. The book is designed for law students taking the subject in the final year of their law degree course or for more advanced courses and is intended to be of interest to all who enjoy tax law. Its purpose is not only to provide an account of the rules but to include citation of the relevant literature from legal periodicals and some discussion of, or reference to, the background material in terms of policy, history or other countries' tax systems.