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Loan relationships deemed releases and debt buybacks
Mar 30, 2012 . Amended draft legislation, Amended Explanatory Note and Guidance . corporation tax rules on 'deemed releases' of loan relationships. . the application of the legislation which will be included in HMRC's Corporate .
http://www.hmrc.gov.uk/drafts/tech-note-loans.pdf

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Loan relationships deemed releases and debt buybacks
Feb 27, 2012 . Draft Legislation, Explanatory Note and Tax Information and Impact Note . corporation tax rules on 'deemed releases' of loan relationships. . application of section 361 CTA 2009 is to be found in HMRC's Corporate. Finance .
http://www.hmrc.gov.uk/drafts/ct-loan-technote.pdf

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  • Ashurst / Publications / Coll -v- HMRC: CGT anti-avoidance
    Coll -v- HMRC: CGT anti-avoidance (Tax newsletter, June 2009). The disposal of shares in return for loan notes, coupled with an intention to redeem the loan .
    http://www.ashurst.com/page.aspx?id_Content=4550

  • CFM34040 - Loan relationships: group continuity: meaning of loan ...
    IP Ltd sells the notes on the market and buys similar loan notes. . apply even though GH Ltd did not receive the same loan notes that KJ Ltd had acquired. . HMRC staff should seek advice from CTIAA (Financial Products Team) where there .
    http://www.hmrc.gov.uk/manuals/cfmmanual/cfm34040.htm

  • SVM111040 - HM Revenue & Customs
    Debts such as debentures and loan notes, even if described as 'unsecured', may therefore rank as 'securities'. Securities only qualify for BR if they gave the .
    http://www.hmrc.gov.uk/manuals/svmanualnew/svm111040.htm

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  • HM Revenue & Customs: Corporation Tax draft legislation
    HM Revenue & Customs (HMRC) has published draft anti-avoidance chapters . A second Technical Note on amendments to the loan relationships legislation .
    http://www.hmrc.gov.uk/drafts/ct.htm

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CFM31090 - Loan relationships: shares acting like debt: equity ...
CFM31090 - Loan relationships: shares acting like debt: equity-linked note. Debt linked to shares: example. AX Ltd issues loan notes for £100,000 to BS Ltd. The .
http://www.hmrc.gov.uk/manuals/cfmmanual/cfm31090.htm

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  • HM Revenue & Customs: Annex III - Qualifying Investments and Loans
    III.1.2 Schedule 20 to the Income and Corporation Taxes Act 1988 describes the types of investments and loans that the Inland Revenue accept as qualifying .
    http://www.hmrc.gov.uk/charities/guidance-notes/annex3/annex_iii.htm

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  • DMBM200230 - Payment processing and accounting: payment ...
    what funding bonds and loan notes are and how to deal with any forms, . to satisfy the tax liability and is submitted to HMRC with the declaration on form CT61.
    http://www.hmrc.gov.uk/manuals/dmbmanual/dmbm200230.htm

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CFM31060 - Loan relationships: money debts arising from the issue ...
For instance loan notes are sometimes issued in exchange, wholly or in part, for shares or securities of another company acquired in a buy-out or take-over.
http://www.hmrc.gov.uk/manuals/cfmmanual/cfm31060.htm

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  • CFM30140 - Loan relationships: a short guide: the meaning of 'loan ...
    For example, a company may buy an asset (such as shares in another company) by issuing a 'loan note'. There has been no lending of money, but the loan note .
    http://www.hmrc.gov.uk/manuals/cfmmanual/cfm30140.htm

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ISAs guidance notes for isa managers
These notes provide general guidance for ISA managers on how to operate the ISA schemes. . HMRC contact addresses and phone numbers. 1.5. How the ISA . Loans. 9.18. Voiding and removing policies of life insurance in ISAs. 9.26. 10.
http://www.hmrc.gov.uk/isa/isa-guidance-notes.pdf

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  • Inheritance Tax: General Approach to IHT Valuation Requests
    Securities - e.g. debentures or loan notes - can qualify for BR (under s.105(1)(b) IHTA) but only ifthey gave the transferor control or contributed to his control .
    http://www.hmrc.gov.uk/manuals/svmanualnew/svm108070.htm

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Disposing of part of your shareholding: company take-overs
A company carrying out a take-over may issue securities, such as loan notes. . If the loan notes are Qualifying Corporate Bonds, you work out the gain as if .
http://www.hmrc.gov.uk/cgt/shares/co-takeover.htm

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  • CTM15515 - HM Revenue & Customs
    Equity notes are loan instruments designed to take advantage of a difference between their treatment in the UK and that in other countries, notably the USA.
    http://www.hmrc.gov.uk/manuals/ctmanual/ctm15515.htm

  • Is a perpetual note debt for tax purposes? (PDF)
    May 3, 2012 . The basic question is not a new one and HMRC's view appeared relatively settled. When the loan relationships regime was first introduced, .
    http://www.slaughterandmay.com/media/1810258/is-a-perpetual-note-debt-for-tax-purposes.pdf

  • Early Redemption Penalties on Loans
    HMRC have recently revised the guidance on their website (see Business Income . paid for early redemption of loans (including mortgages) are a deductible expense. . One note of caution – the guidance goes on to explain that it refers to .
    http://www.taxinsider.co.uk/326-Early_Redemption_Penalties_on_Loans.html

  • CFM35490 - Loan relationships: connected companies and ...
    Such a balance sheet would show the loan notes at fair value: no identifiable adjustment for impairment would have been made. Therefore CTA09/S362 does .
    http://www.hmrc.gov.uk/manuals/cfmmanual/cfm35490.htm

  • Tax Update
    consequent changes to the sale consideration of a sale of the Loan Notes to the trustees and so to the taxpayer's tax liability. Put shortly, HMRC contended that .
    http://www.rpc.co.uk/index.php?task=download&option=com_flexicontent&fid=22&cid=16534&id=1829

  • Corporation Tax: Grouping Rules
    HM Revenue & Customs (HMRC) has received a number of clearance applications in respect of loan notes that are issued by companies that provide the lender .
    http://www.hmrc.gov.uk/budget2012/tiin-0900.pdf

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Mclaughlin v HMRC – avoidance scheme succeeds - Lexology
Apr 5, 2012 . Put shortly, HMRC contended that under the “composite” transaction, Mr Gower had no right to call for or deal with the Loan Notes, which .
http://www.lexology.com/library/detail.aspx?g=4d011f79-7089-4f14-a47c-b6bdef964a6b

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  • Consultation on draft legislation for Finance Bill 2012 - HM Treasury
    Mar 13, 2012 . The draft legislation, explanatory note and Tax Information and Impact . under the corporation tax rules on 'deemed releases' of loan relationships. . Technical note and Statutory Instrument (HMRC website, opens in new .
    http://www.hm-treasury.gov.uk/finance_bill_2012_consultation.htm

  • Ashurst / Publications / William Blumenthal -v- HMRC (Tax ...
    William Blumenthal -v- HMRC (Tax newsletter, August 2012). Facts. This case(1) concerned a scheme offered to holders of loan notes issued by O2 on a .
    http://www.ashurst.com/page.aspx?id_Content=8197

  • PLC - Lending: General
    1, Zero coupon loan notes, Glossary, Maintained. 2, Worldwide debt cap: HMRC announces changes. An update about HMRC's technical note, published on 9 .
    http://finance.practicallaw.com/topic1-103-2033?params=true&num=20&&_charset_=UTF-8&sv=3-201-3706&rt=All&sort=title&isasc=0

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  • Tax avoidance loophole that costs HMRC a small fortune | Money ...
    Jun 22, 2012 . Annual season ticket loans have been around for decades and are approved by HMRC. But what is striking is how company directors have .
    http://www.guardian.co.uk/money/2012/jun/22/tax-avoidance-loophole

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TC01870
Mar 6, 2012 . (b) as HMRC contend, section 71(1) did not apply to the Appointment, then the. Loan Notes continued to be vested in the trustees, and so the .
http://clients.squareeye.net/uploads/pump/documents/McLaughlin06032012.pdf

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  • Courts and Tribunals
    May 4, 2012 . As AG was non-UK domiciled, and the loan notes were situated outside the UK, no CGT was payable on the disposal. HMRC contended that .
    http://www.bloomsburyprofessionalonline.com/applib/newsitem/171/courts-and-tribunals

  • The First-Tier Tax Tribunal Has Decided That A Scheme To Avoid ...
    4 days ago . Based on Harding v HMRC 79 TC 885, HMRC argued that the loan notes remained non-QCBs, even after the contingent provision in the Deed .
    http://www.mondaq.com/x/195990/tax+authorities/The+FirstTier+Tax+Tribunal+Has+Decided+That+A+Scheme+To+Avoid+Tax+By+Temporarily+Devaluing+Consideration+Loan+Notes+Did+Not+Work

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000-000_TA_1010_Transactions in securities.indd
the equity Newco plus loan notes. In such circumstances, HMRC normally gave clearance to A and B, and refused clearance for P as respects the loan stock.
http://www.taxcounsel.co.uk/ImageLibrary/000-000_TA_1010_Transactions%20in%20securities.pdf

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  • HMRC turn attention to the taxation of interest - Herbert Smith
    Mar 28, 2012 . HMRC has published proposals (in the form of a consultation . This will be relevant for any loans where interest is paid by way of PIK notes.
    http://www.herbertsmith.com/Publications/taxebulletin28032012.htm

  • P11D Guide (2012)
    of HMRC. See booklet 480 chapter 2. When do you need a form P11D(b)? . interest-free and low interest loans . Note that a loan made by a person other .
    http://www.hmrc.gov.uk/guidance/p11dguide.pdf

  • HMRC turn attention to the taxation of interest - Herbert Smith
    Mar 28, 2012 . HMRC has published proposals (in the form of a consultation . This will be relevant for any loans where interest is paid by way of PIK notes.
    http://www.herbertsmith.com/Publications/taxebulletin28032012.htm

  • HM Revenue & Customs: Pension Schemes - news
    HMRC has published a Tax Information and Impact Note (TIIN) for Pension . able to provide loans or release tax-free cash from their pensions before age 55.
    http://www.hmrc.gov.uk/pensionschemes/news.htm

  • Directors' loan accounts and Corporation Tax explained
    If your director's loan account is overdrawn, your company must pay tax on any . This loan is sometimes known to HMRC as a 'loan to participators'. . Please note that these are not necessarily the same definitions used by other HMRC tax .
    http://www.hmrc.gov.uk/ct/managing/director-loan.htm

  • CFM32030 - Loan relationships: non-trading profits and deficits
    it has no trade, such as an investment company, or; it has a trade, but it holds a loan relationship for investment or other non-trade purposes. Note that a property .
    http://www.hmrc.gov.uk/manuals/cfmmanual/cfm32030.htm

  • INTM580030 - HM Revenue & Customs
    Although the revolving and capex facilities are often detailed in the loan . satisfying the interest liability through the issue of further loan notes called PIK notes.
    http://www.hmrc.gov.uk/manuals/intmanual/intm580030.htm

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  • Bill 5 CC/SC(08) 27 loan relationships appendix A explanatory notes
    Corporation Tax: Bill 5. Part 6: Loan relationships. July 2008: Committee paper CC/SC (08) 27. Chapter 1: Continuity on transfers of loans within groups or on .
    http://www.hmrc.gov.uk/rewrite/cc-sc-08-27-loan-rel-ens.pdf

  • Common PAYE Coding Notice entries explained
    The note on your Coding Notice will tell you what Married Couple's Allowance . higher rate tax relief on pensions you're paying into; loss relief; loan interest . This enables HMRC to collect the correct amount of owed tax through PAYE (Pay .
    http://www.hmrc.gov.uk/incometax/understand-p2-exp.htm

  • HM Revenue & Customs: Detailed guidance notes for charities
    individuals & employees. You are here: Charities > Charities: detailed Guidance Notes . 6. Audits by HMRC Charities. 7 . Qualifying investments and loans. iii .
    http://www.hmrc.gov.uk/charities/guidance-notes/intro.htm

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INTM332040 - HM Revenue & Customs
The brief facts are that an Indonesian trading group (Indofood) wished to raise finance using the issue of internationally marketed loan notes. It did so using a .
http://www.hmrc.gov.uk/manuals/intmanual/intm332040.htm

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  • P11D WS4 (2012) Interest-free and low interest laons 2011-12
    Note to employer. You do not have to use this . provided interest-free or low interest loans for a director, or an employee who . HMRC 09/11. Employer details .
    http://www.hmrc.gov.uk/ebu/p11dws4.pdf

  • Overview of Tax Legislation
    Mar 21, 2012 . addition, HMRC will develop the guidance and resources it makes . where it issues loan notes carrying a right to conversion into shares or .
    http://www.hmrc.gov.uk/budget2012/ootlar-main.pdf

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CSLM17025 - HM Revenue & Customs
The new employer makes Student Loan deductions; Deductions continue until employer receives a Stop Notice from HMRC. Note: HMRC will not issue a Start .
http://www.hmrc.gov.uk/manuals/cslmanual/cslm17025.htm

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HM Revenue & Customs: HMRC Technical Note
Nov 9, 2009 . HMRC Technical Note . If the company has a non-trading loan relationships deficit, section 404 Income and Corporation Tax Act (ICTA) 1988 .
http://www.hmrc.gov.uk/ctsa/debt-cap-tn.htm

SA108 Notes 2012
Mar 25, 2012 . Tax return: Capital gains summary notes: Page CGN 1. HMRC 12/11 . gains on the recovery of certain loans and guarantee payments .
http://www.hmrc.gov.uk/worksheets/sa108-notes.pdf




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