DEBT

Debt indemnity arising from share sale did not give rise to a remittance to the UK

The targeted anti-avoidance provisions that contain motive tests are being applied in ways which prevent the tax system from operating effectively, writes Constantine Christofi (RPC).

David Southern QC

David Southern QC (Field Court Tax Chambers) provides a guide to the tax consequences of loan transfers.

Paul Pritchard

Companies emerging from the pandemic may undertake a debt restructuring. Paul Pritchard (FTI Consulting) discusses current tax issues with debt releases.

Chris Holmes

David Hicks

Chris Holmes (BDO) and David Hicks (Charles Russell Speechlys) consider the tax consequences of releasing wholly or partly recoverable inter-company debts.

Mandipa Soni

Edward Brown

Mandipa Soni and Edward Brown (Grant Thornton) discuss the taxation of loan relationships and derivatives for UK corporates, with a focus on convertible securities from the borrower’s perspective.

Nicholas Macpherson

Nicholas Macpherson, former permanent secretary to three chancellors, considers a potential solution to reducing the public sector debt.

Helen Buchanan

John Tolman

Helen Buchanan and John Tolman (Freshfields Bruckhaus Deringer) examine what is effectively the pilot episode for an upcoming courtroom drama.

Alistair Godwin

Alistair Godwin (Grant Thornton) focuses on the Taxes Acts in order to bring out some of the key features of a ‘security’ that are useful in practice.

Helen Chadwick Mo Malhotra Ben Moseley

Ben Moseley, Helen Chadwick and Mo Malhotra (Deloitte) examine the key tax points in relation to the actions corporate treasurers are considering in response to economic impact of the Covid-19 pandemic.

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