Weil Tax BLOG - Feed https://tax.weil.com/category/uk-tax/straight-to-the-point/ Views and developments from the Tax Department at Weil Fri, 24 Apr 2026 11:53:35 +0000 hourly 1 Best Corporate Tax Practice 2019 https://tax.weil.com/uk-tax/market-recognition/best-corporate-tax-practice-2019/ Wed, 22 May 2019 13:16:04 +0000 Weil Tax Blog http://tax.weil.com/?p=549 Weil’s London Tax team was honored with the Best Corporate Tax Practice Award at the annual Tolley’s Taxation Awards, which took place on May 16, 2019, in London. The team, led by partner Oliver Walker, has advised on a number of high-profile transactions during the past year. The team was praised for its thought leadership, having

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]]> Weil’s London Tax team was honored with the Best Corporate Tax Practice Award at the annual Tolley’s Taxation Awards, which took place on May 16, 2019, in London. The team, led by partner Oliver Walker, has advised on a number of high-profile transactions during the past year. The team was praised for its thought leadership, having

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]]> Entrepreneurs’ Relief – FA 2019 Changes https://tax.weil.com/uk-tax/straight-to-the-point/entrepreneurs-relief-fa-2019-changes/ Tue, 21 May 2019 13:51:55 +0000 Oliver Walker http://tax.weil.com/?p=510 Speed read This year’s Finance Act consolidated various changes to the Entrepreneurs’ Relief (“ER”) regime. There are two key changes that may be of particular relevance to corporate acquisitions: new (additional) economic ownership tests that must be satisfied in orderfor an individual holding shares in a company to benefit from ER; and a new option

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]]> Speed read This year’s Finance Act consolidated various changes to the Entrepreneurs’ Relief (“ER”) regime. There are two key changes that may be of particular relevance to corporate acquisitions: new (additional) economic ownership tests that must be satisfied in orderfor an individual holding shares in a company to benefit from ER; and a new option

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]]> New Tax Developments for Insolvency and Restructuring Deals https://tax.weil.com/latest-thinking/new-tax-developments-for-insolvency-and-restructuring-deals/ Mon, 13 May 2019 15:19:41 +0000 Oliver Walker Ellie Marques http://tax.weil.com/?p=509 The below is a quick snapshot of three recent tax-related developments in the insolvency and restructuring sphere. Farnborough – appointment of a receiver and tax grouping The Court of Appeal recently handed down its judgment in the case of Farnborough Airport Properties Co and another v Revenue and Customs Commissioners, which concerned the effect of

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]]> The below is a quick snapshot of three recent tax-related developments in the insolvency and restructuring sphere. Farnborough – appointment of a receiver and tax grouping The Court of Appeal recently handed down its judgment in the case of Farnborough Airport Properties Co and another v Revenue and Customs Commissioners, which concerned the effect of

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]]> Enterprise Management Incentives (EMI) Schemes https://tax.weil.com/uk-tax/hmrc/enterprise-management-incentives-emi-schemes/ Thu, 11 Apr 2019 11:30:53 +0000 Erica Rees http://tax.weil.com/?p=493 On 6 April 2018, the EU State Aid approval which is critical to the operation of Enterprise Management Incentive (“EMI”) options expired.  Two days beforehand, HMRC published Issue 27 of its Employment Related Securities Bulletin, setting out information regarding the implications. Due to the limited availability of the regime, the tax reliefs arising in respect

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]]> On 6 April 2018, the EU State Aid approval which is critical to the operation of Enterprise Management Incentive (“EMI”) options expired.  Two days beforehand, HMRC published Issue 27 of its Employment Related Securities Bulletin, setting out information regarding the implications. Due to the limited availability of the regime, the tax reliefs arising in respect

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]]> CJEU Rulings – Bad News for Private Equity? https://tax.weil.com/uk-tax/straight-to-the-point/cjeu-rulings-bad-news-for-private-equity/ Wed, 03 Apr 2019 16:21:27 +0000 Oliver Walker Erica Rees http://tax.weil.com/?p=508 Speed read: The Court of Justice of the European Union (the “CJEU”) has held that EU-wide exemptions from withholding tax on dividends and interest may be disapplied by member states, where it can be shown that there has been an abuse of EU rights. The judgment is particularly relevant to EU holding company structures of

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]]> Speed read: The Court of Justice of the European Union (the “CJEU”) has held that EU-wide exemptions from withholding tax on dividends and interest may be disapplied by member states, where it can be shown that there has been an abuse of EU rights. The judgment is particularly relevant to EU holding company structures of

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]]> Changing the Insolvency Waterfall – HMRC to Become a Preferential Creditor Again https://tax.weil.com/uk-tax/hmrc/changing-the-insolvency-waterfall-hmrc-to-become-a-preferential-creditor-again/ Thu, 01 Nov 2018 16:40:36 +0000 Adam Plainer Mark Lawford http://tax.weil.com/?p=507 The recent budget flagged the re-introduction of preferential creditor status for the UK tax authority (HMRC) in insolvencies in certain limited circumstances. The changes will be effective from 6 April 2020 (no draft legislation is available yet) and will provide for HMRC to become a preferred creditor in relation to, in broad terms, amounts collected

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]]> The recent budget flagged the re-introduction of preferential creditor status for the UK tax authority (HMRC) in insolvencies in certain limited circumstances. The changes will be effective from 6 April 2020 (no draft legislation is available yet) and will provide for HMRC to become a preferred creditor in relation to, in broad terms, amounts collected

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]]> Autumn Budget 2018 https://tax.weil.com/uk-tax/straight-to-the-point/autumn-budget-2018/ Mon, 29 Oct 2018 22:10:19 +0000 Oliver Walker http://tax.weil.com/?p=506 The Chancellor delivered the 2018 Autumn Budget this afternoon. Here is a summary of the key announcements.

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]]> The Chancellor delivered the 2018 Autumn Budget this afternoon. Here is a summary of the key announcements.

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]]> Growing Investment: How the New QPP Exemption Will Simplify Processes and Encourage Debt Investment into the UK https://tax.weil.com/uk-tax/straight-to-the-point/growing-investment-how-the-new-qpp-exemption-will-simplify-processes-and-encourage-debt-investment-into-the-uk/ Tue, 09 Oct 2018 10:53:02 +0000 Stuart Pibworth http://tax.weil.com/?p=505 Where a UK corporate debtor makes payments of yearly interest to, among others, non-UK creditors, the debtor will be required to withhold an amount representing UK income tax (currently at a rate of 20%) from that payment and account to HMRC for the same. Generally, this mechanic is referred to as a ‘withholding tax’. However,

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]]> Where a UK corporate debtor makes payments of yearly interest to, among others, non-UK creditors, the debtor will be required to withhold an amount representing UK income tax (currently at a rate of 20%) from that payment and account to HMRC for the same. Generally, this mechanic is referred to as a ‘withholding tax’. However,

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]]> Debt Waivers in Cross-border Restructuring: Problems With the UK’s Anti-hybrid Legislation https://tax.weil.com/uk-tax/straight-to-the-point/debt-waivers-in-cross-border-restructuring-problems-with-the-uks-anti-hybrid-legislation/ Mon, 01 Oct 2018 10:25:23 +0000 Weil Tax Blog http://tax.weil.com/?p=504 Recent changes to UK tax law appear to have resulted in a stealth increase to the number of situations in which a release of loans in cross-border restructuring scenarios can be taxable in the UK. The date on which a loan was entered into or drawn down now appears to have a material effect on

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]]> Recent changes to UK tax law appear to have resulted in a stealth increase to the number of situations in which a release of loans in cross-border restructuring scenarios can be taxable in the UK. The date on which a loan was entered into or drawn down now appears to have a material effect on

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]]> Ordinary share capital: HMRC shares its views https://tax.weil.com/uk-tax/straight-to-the-point/ordinary-share-capital-hmrc-shares-its-views/ Mon, 24 Sep 2018 15:14:49 +0000 Stuart Pibworth http://tax.weil.com/?p=503 For UK tax purposes, it is often necessary to determine whether shares constitute ordinary share capital (OSC). For instance, this might be necessary when considering, amongst others: a number of the group relief rules, such as corporation tax, capital gains tax and stamp duty the substantial shareholdings exemption the corporate dividend exemption entrepreneurs relief tax-advantaged

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]]> For UK tax purposes, it is often necessary to determine whether shares constitute ordinary share capital (OSC). For instance, this might be necessary when considering, amongst others: a number of the group relief rules, such as corporation tax, capital gains tax and stamp duty the substantial shareholdings exemption the corporate dividend exemption entrepreneurs relief tax-advantaged

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