Ashley Greenbank (Macfarlanes) examines the draft regulations issued following the Autumn Statement announcement to prevent the use of cancellation schemes as a means of reducing stamp duty and SDRT costs on takeovers
Toby Price and Martin Walker (Deloitte) consider the potential stamp tax traps arising on IPOs, including pre-IPO reorganisations and overallotment (or greenshoe) options, as well as offering practical solutions
Mark Middleditch (Allen & Overy) provides this month’s update, including: the limits of the purposive approach in tax avoidance cases; accelerated payments and DOTAS; draft changes on loan relationships and derivative contracts; notice clauses in tax indemnities; and the new HMRC Stamp Taxes on Shares Manual
For any transaction involving bonds or notes, there are a number of potential difficulties that may arise, which may include issues involving stamp taxes, VAT, withholding tax, FATCA, and the tax treatment of the bond issuer and bondholders. Eloise Walker and Abigail McGregor provide a handy practice guide for advisers
Views from tax professionals on missed opportunities in the Budget.