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Taxation of Companies and Company Reconstructions
Taxation of Companies and Company Reconstructions
9th Edition
Number of volumes: 3
Series:  Sweet & Maxwell's Tax Library
Practice Area:  Taxation Law
ISBN:  9780421827202
Subscription Information: 3 releases a year, Non-Subscribable Product
Format:  Looseleaf
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Taxation of Companies and Company Reconstructions covers key aspects of corporate taxation law, showing you exactly how tax provisions apply in practice. Although the text is being continually modernised, the carefully structured style that has long been the hallmark of this book is retained. Each subject is examined from first principles before moving into finer points of detailed explanation.

  • Hear what the experts have to say on the re-write of corporation tax law
  • Includes commentary on the Corporation Tax Acts
  • The information has been revised and re-presented to give you quicker access to what you need
  • Includes commentary on cases, statutes and statutory instruments and European legislation

  • Covers key aspects of company taxation law
  • Shows exactly how tax provisions apply in practice
  • Illustrates how best to arrange asset transfers for company reconstructions
  • Gives you guidance on distributions, overseas matters, groups and reconstructions
  • Explains the rules of loan relationships and withholding tax, derivatives contracts legislation and intangible fixed assets legislation
  • Outlines the relief in Corporate Reconstruction
  • Contains in-depth technical analysis with authoritative discussion of points of statutory interpretation
  • Provides helpful guidance and analysis of case law and legislation on company taxation
  • Gives practical, problem-solving advice to show exactly how provisions apply in practice
  • Uses cases, commentary and worked examples
  • Offers commentary on relevant passages in the HMRC Manuals
  • Updated three times a year, so you remain fully abreast of developments in taxation law


    Service Information
    Table of Abbreviations

    Table of Cases
    Table of Statutes
    Table of Statutory Instruments
    Table of European Legislation
    Division A: Corporation Tax
    A1 The Charge to Corporation Tax   
    A2 The Basis of Assessment and Rates of Tax 
    A3 Corporation Tax on Distributions 
    A4 Accounts in Foreign Currency 
    A5 Companies in Partnership    
    A6 Trade and Property Losses
    A7 Change of Ownership of Tax Loss Companies 
    A8 Companies with Investment Businesses 
    A9 Investment Trusts, Venture Capital Trusts, Unit Trusts and Open-Ended Investment Companies 
    A10 Real Estate Investment Trusts (REITS)

    Division B: Compliance and Litigation

    B1 Self-Assessment and Recovery of Tax 
    B2 Collection      
    B3 Determinations, Enquiries and Discovery 
    B4 Information and Inspection Powers 
    B5 Penalties  
    B6 Reviews and Appeals  
    B7 Alternative Dispute Resolution  
    Division C: Capital Allowances for Plant and Machinery
    C1 Capital Allowances for Plant and Machinery 
    C2 Meaning of Plant 
    C3 Ownership of Fixtures 
    C4 Equipment Leasing 
    Division D: Close Companies
    D1 Possession of “Control”
    D2 Close Companies
    D3 Close Companies: Loans to Participators 

    Division E: Distributions
    E1 Distributions  
    E2 Taxation of Distributions 
    E3 Stock Dividend Options 
    E4 Companies Purchasing Their own Shares   
    Division G: Intangible Fixed Assets

    G1 Intangible Fixed Assets Legislation  
    G2 Intangible Fixed Assets Legislation – Groups of Companies 
    G3 Intangible Fixed Assets Legislation – Reconstructions and Migrations 
    Division H: Derivatives
    H1 Derivative Contracts Legislation   
    H2 Derivative Contracts used for Hedging  
    H3 Derivative Contracts Legislation – Interaction with the TCGA 1992 
    H4 Taxation Treatment of Derivative Contracts which  fall outside the Derivative Contracts Legislation
    H5 Common Derivative Contracts

    Division J: Transfer Pricing 

    J1 Transfer Pricing  
    J2 Associated Persons 
    J3 Transfer Pricing and Loan Finance 
    J4 Exemption for Small and Medium-Sized Enterprises J5 Avoiding Double Taxation  
    J6 Advance Pricing Agreements 
    J7 Trading Stock: Deemed Consideration  
    Division K: Loan Relationships

    K1 Loan Relationships Legislation – An Introduction
    K2 Scope of the Loan Relationships Legislation 
    K3 Recognition of Profits and Losses 
    K4 Convertible & Exchangeable Securities
    K5 Anti-Avoidance Provisions 
    K6 Connected Companies, Impairment Relief and Deeply Discounted Securities
    K7 Groups and Consortiums  
    K8 European Cross-Border Transfers, Mergers and Reorganisations 
    K9 Witholding Tax – An Overview 

    Division L: Deemed Loan Relationships and Stock Loans

    L1 Deemed Loan Relationships and Stock Loans
    L2 Tax Treatment of Sales and Repurchases of Securities 
    L3 Stock Loans and Manufactured Payments
    L4 Structured Finance Arrangements
    L5 Transfers of Income Streams
    L6 Shares Accounted for as Liabilities 
    L7 Disguised Interest 

    Division M: Worldwide Debt Cap Legislation

    M1 Worldwide Debt Cap Legislation – Overview and
    M2 The Gateway Test and Exclusion for Qualifying Financial Services Groups
    M3 Disallowance of Funding Expenses and Exemption for Financing Income
    M4 Measures Designed to Make the Worldwide Debt Cap Legislation EU Compliant

    Division N Diverted Profits Tax;

    N1 Overview
    N2 Companies within the Charge to Corporation Tax
    N3 Non-UK-Resident Company Avoiding a UK Taxable Presence
    Division P: Non-Resident Companies
    P1 The Charge to Corporation Tax
    P2 Company Residence 
    P3 UK Permanent Establishment
    P4 Investment in United Kingdom Property
    P5 International Movement of Capital 
    Division Q: CFCs 

    Q1 Controlled Foreign Companies
    Q2 The CFC Charge
    Q3 CFC Charge Gateway - Profits Attributable to UK Activities
    Q4 Non-Trading Finance Profits
    Q5 Trading Finance Profits
    Q7 Control
    Q6 Captive Insurance Business and Solo Consolidation
    Q8 CFC Residence and Exemptions from a CFC Charge

    Division R: Double Tax Relief

    R1 Double Tax Relief – An Overview
    R2 Relief for Underlying Tax on Dividends 
    R3 Manner of Giving Relief by Credit
    R4 Double Tax Credit Relief – Trade Income
    R5 Schemes and Arrangements Designed to Increase Double Tax Credit Relief
    R6 Exemption for Taxable Profits of Foreign Permanent Establishments 

    Division S: EU Law   
    S1 Freedom of Establishment

    Division T: Group Relief 
    T1 Group Relief: Group Structure
    T2 Equity Holders 
    T3 The Surrender of Group Relief
    T4 Consortium Relief
    T5 Group Claims: EEA Losses
    Division V: Group CGT and SDLT

    V1 Chargeable Gains and Groups
    V2 Share and Debenture Issues and Exchanges 
    V3 Section 179: The Degrouping Charge
    V4 Depreciatory Transactions Within a Group
    V5 Pre-Entry Losses
    V6 FA 2006 Restrictions on Buying Losses and Gains
    V7 Sales of Substantial Shareholdings
    V8 SDLT and Stamp Duty Group Relief
    Division W: Reconstructions

    W1 Corporate Restructuring: Outline of Reliefs
    W2 Demergers
    W3 Reconstructions: Shareholdings and Asset Transfers
    W4 Change in Ownership of Trade
    W5 SDLT and Stamp Duty Reconstruction Reliefs
    W6 Transactions in Securities
    W7 Cross Border Transfers and Mergers



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