Taxation of Company Reorganisations
Taxation of Company Reorganisations

Author: Pete Miller

Publisher: Bloomsbury Professional

Published: 2020-11-11

Total Pages: 0

ISBN-13: 9781526511492

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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)

Taxation of Company Reorganisations
Taxation of Company Reorganisations

Author: Pete Miller

Publisher: Bloomsbury Publishing

Published: 2020-10-05

Total Pages: 749

ISBN-13: 1526511517

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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)

Taxation of Company Reorganisations in Ireland
Taxation of Company Reorganisations in Ireland

Author: Evelyn Ford

Publisher: A&C Black

Published: 2011-08-31

Total Pages: 477

ISBN-13: 184766377X

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This unique new title is the only Irish tax publication which provides an in-depth and comprehensive analysis of the Irish tax issues arising in company reorganisations and reconstructions. The book adopts a practical approach to examining the principal considerations arising from the types of reorganisations typically undertaken by Irish companies. The text includes a number of worked examples, case studies and tax planning points relevant to this complex area. Providing a comprehensive analysis of relevance to tax practitioners in both large and small tax firms, it considers the practical application of tax law in key areas, including:- Restructurings in the context of incorporation - Group reorganisations/reconstructions - Restructurings for sale - Share capital reorganisations - Earn outs and long term incentive schemes - Anti-avoidance - An introduction to relevant company law and accounting issues is also included. EURO: 175

European Union Corporate Tax Law
European Union Corporate Tax Law

Author: Christiana HJI Panayi

Publisher: Cambridge University Press

Published: 2013-05-09

Total Pages: 413

ISBN-13: 1107354986

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How does EU law affect Member State corporate tax systems and the cross-border activities of companies? This unique study traces the historical development of EU corporate tax law and provides an in-depth analysis of a number of issues affecting companies, groups of companies and permanent establishments. Existing legislation, soft-law and the case-law of the Court of Justice are examined. The proposed CCCTB Directive and its potential application through enhanced co-operation are also considered. In addition to the tax issues pertaining to direct investment, the author examines the taxation of passive investment income, corporate reorganisations, exit taxes and the restrictive effect of domestic anti-abuse regimes. By doing so, the convergences and divergences arising from the interplay of EU corporate tax law and international tax law, especially the OECD model, are uncovered and highlighted.

Luxembourg in International Tax Planning
Luxembourg in International Tax Planning

Author: Philip J. Warner

Publisher: IBFD

Published: 2004

Total Pages: 588

ISBN-13: 9076078610

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Study, divided into five parts: a short introduction to Luxembourg as a country and financial centre; calculation of profits taxes and other taxes to which a fully-taxable resident business is subject; the fully-taxable "special purposes vehicles" available in Luxembourg including banking and reinsurance; tax exempt vehicles, the 1929 holding company and investment funds; and corporate reorganizations and examples of how Luxembourg could be used in international tax planning

Employment Law Review
Employment Law Review

Author: Erika C Collins

Publisher: Law Business Research Ltd.

Published: 2017-04-07

Total Pages: 1263

ISBN-13: 1912377683

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The Employment Law Review, edited by Erika C Collins of Proskauer Rose LLP, serves as a tool to help legal practitioners and human resources professionals identify issues that present challenges to their clients and companies. As well as in-depth examinations of employment law in 48 jurisdictions, the book provides further general interest chapters covering the variety of employment-related issues that arise during cross-border merger and acquisition transactions, aiding practitioners and human resources professionals who conduct due diligence and provide other employment-related support in connection with cross-border corporate M&A deals. Other chapters deal with global diversity and inclusion initiatives across the globe, social media and mobile device management policies, and the interplay between religion and employment law. Contributors include: Els de Wind, Van Doorne; Annie Elfassi, Loyens Loeff. "e;Excellent publication, very helpful in my day to day work."e; - Mr Frederic Thoral, Head of HR, BNP Paribas"e;Excellent coverage and detail on each country is brilliant."e; - Mr Raani Costelloe, General manager of Legal and Business Affairs, Sony music Entertainment, Australia"e;An excellent resource for in-house counsel for a company with an international footprint."e; - Mr John R Pendergast, Senior Counsel, BASF Corporation, USA"e;It's invaluable to any lawyer dealing with cross-border and privacy-related employment issues and is a cornerstone to my own legal research"e; - Oran Kiazim, Vice President, Global Privacy, SterlingBackcheck, UK

Tax Implications of Brexit
Tax Implications of Brexit

Author: Nicola Saccardo

Publisher: Bloomsbury Publishing

Published: 2021-05-21

Total Pages: 528

ISBN-13: 1526516810

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Tax Implications of Brexit is an essential guide for anyone advising businesses trading in either the United Kingdom or the European Union post-Brexit. In two parts, this title provides an in-depth analysis of the tax ramifications of Brexit in both the United Kingdom and EU Member States, helping to identify immediate and future issues that could be faced post-Brexit, and how to mitigate any risks. Part One features subject-specific chapters which deal with the UK statutory regime after 2020 as well as the impact of Brexit on VAT, customs and excise duties and State Aid legislation. Part Two is split into country chapters dealing with the tax implications in the single jurisdictions (the United Kingdom and EU Member States) for cross-border investments between the United Kingdom and the EU and for UK-EU cross-border reorganisations. This book is essential reading for tax professionals advising businesses trading in the United Kingdom or in the European Union, but also tax managers of those businesses. Tax Implications of Brexit includes contributions from Barbara Belgrano, Conor Quigley QC, Julian Ghosh QC, Kelly Stricklin-Coutinho, Nicola Saccardo, Roderick Cordara QC, Timothy Lyons QC and a plethora of highly respected tax experts from EU jurisdictions.

Feeney: The Taxation of Companies 2019
Feeney: The Taxation of Companies 2019

Author: Michael Feeney

Publisher: Bloomsbury Publishing

Published: 2019-04-19

Total Pages: 2416

ISBN-13: 1526506920

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This key book provides the most comprehensive analysis and commentary available on the taxation of companies in Ireland. Now in its 23rd year of publication, this extremely practical book features detailed worked examples and extensive references to case law throughout the work. The guidance and advice outlines how to successfully apply the new tax reliefs, keeping your clients' tax liabilities as low as possible. This new edition has been updated to the Finance Act 2018 and incorporates the many substantive legal changes that have taken place in the last year, including: - The new controlled foreign companies legislation: whereby, for Irish tax purposes, undistributed income of controlled foreign subsidiaries may be attributed to an Irish controlling company of those subsidiaries. - The capital gains tax exit charge legislation, which has been completely re-written and substituted for the existing legislation. - Film relief, which has been extended for another four years, to 31 December 2024, but which has also been extensively amended There have also been numerous legal smaller changes that have been addressed and incorporated into this new edition, such as the technical change in specified tangible assets to the 80% restriction on allowable capital allowances, the extension of accelerated capital allowances to expenditure on energy-efficient equipment, the accelerated capital allowances for equipment and buildings for childcare centres or fitness centres for employee and the extension of relief for start-up companies.