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Author : Julian Ghosh,Ian Johnson
Publisher : Unknown
Page : 128 pages
File Size : 40,7 Mb
Release : 2003
Category : Financial instruments
ISBN : 0406961492
Author : Julian Ghosh,Ian Johnson
Publisher : Butterworths
Page : 128 pages
File Size : 53,7 Mb
Release : 1998
Category : Taxation
ISBN : 0406985464
Author : David Southern
Publisher : Bloomsbury Professional
Page : 773 pages
File Size : 47,7 Mb
Release : 2007
Category : Business & Economics
ISBN : 1845921879
Formerly known as Taxation of Corporate Debt, Foreign Exchange and Derivative Contracts, Taxation of Loan Relationships and Derivative Contracts 8th edition has been comprehensively revised and updated in light of the recent major developments in the subject. The expert guidance and clearly presented practical information contained in the book demonstrate exactly how the developments in this complex field will affect the tax treatment of company financing. Corporate tax practitioners with a copy of Taxation of Loan Relationships and Derivative Contracts 8th edition on their desk will be able to handle their clients' finance arrangements with confidence and accuracy.
Author : Julian Ghosh,Ian Johnson,Paul Miller
Publisher : Unknown
Page : 800 pages
File Size : 42,6 Mb
Release : 2009-04-14
Category : Electronic
ISBN : 1405747161
Offering invaluable tax planning help for the tax specialist, Taxation of Corporate Debt and Derivatives is a highly practical publication, ideal for the busy tax practitioner and lawyer. Debt and Treasury management occupies an increasing proportion of the work of tax practitioners. With considerable legislation to get to grips with, this publication, updated twice per annum, offers a concise and comprehensive version of the law in this area. This publication examines, in detail, each of the regimes involving: * Foreign exchange transactions * Financial instruments (such as options, debt contracts, currency swaps) * Corporate debt, i.e. the loan relationship provisions * Anti-avoidance provisions including thin capitalisation, funding bonds etc
Author : David Southern
Publisher : Unknown
Page : 536 pages
File Size : 48,5 Mb
Release : 2002
Category : Contracts
ISBN : 0754517888
A new regime for monetary transactions was heralded by the three separate tax codes introduced from 1993 to 1996 for foreign exchange, financial instruments and loan relationships. Now the proposals for the Finance Act 2002 radically consolidates, extends and recasts the new rules and new anti-avoidance provisions have already taken effect from 26 July 2001.
Author : David Southern
Publisher : Bloomsbury Publishing
Page : 717 pages
File Size : 43,5 Mb
Release : 2017-01-13
Category : Business & Economics
ISBN : 9781784511357
Taxation of Loan Relationships and Derivative Contracts, Tenth Edition, is updated in line with the Finance Act 2015 which brings in significant changes to the loan relation rules. In addition, it includes changes to both UK and International Accounting Standards. This new edition covers developments in the Basic Erosion and Profit Shifting (BEPs) project and the related new climate and wider concept of tax avoidance (GAAR). The chapters covering accounting framework, reorganisations and international aspects have been significantly updated since the previous edition and new chapters have been added with a summary of all relevant cases and a chapter covering Islamic Finance. Covers the following: The Taxation of Finance Accounting under IFRS and Modified UK GAAP The Scheme of the Legislation Loan Relationships: Scope and Definition Loan Relationships: General Computational Provisions Loan Relationships: Special Computational Provisions Impairment Losses Foreign Exchange and Hedging/Deferral Interest Securities Reorganisations, Acquisitions and Disposals Special Companies Derivative Contracts – Definition and Scope Derivative Contracts – Measurement of Profits Embedded Derivatives Worldwide Debt Cap Transfer Pricing Stock Lending and Repos International Aspects Islamic Finance Cases Appendices
Author : Brian J. Arnold,Hugh J. Ault,Graeme Cooper
Publisher : Kluwer Law International B.V.
Page : 655 pages
File Size : 46,9 Mb
Release : 2019-12-09
Category : Law
ISBN : 9789403510903
Comparative Income Taxation A Structural Analysis Fourth Edition Hugh J. Ault, Brian J. Arnold & Graeme S. Cooper In complex national income tax systems, structural and design variations from one country to another present major obstacles to the kind of comparative understanding that economic globalization requires. Hence the great significance of this outstanding book, highly acclaimed through three previous editions and now thoroughly updated to encompass the latest changes and trends. In it, leading authorities from eleven of the world’s most important national taxation systems each contribute their particular expertise to a study of specific crucial problems of tax design. In addition to the nine countries covered in previous editions—Australia, Canada, France, Germany, Japan, the Netherlands, Sweden, the United Kingdom and the United States—China and India have now been added to provide the perspective of developing countries. Individually authored country descriptions outline the climate and institutional framework in which each of the eleven national taxation systems’ substantive rules operate. All the country descriptions are analyzed in accordance with a common format to facilitate comparisons of the ways in which the countries’ tax systems are similar and in which they differ. They form the background to an expertly informed comparative analysis focusing on three major areas: basic income taxation, taxation of business organizations and international taxation. Most of the rules especially important for international business and investment are dealt with here, including (among many others) rules on the following: classification of business entities; taxation of corporations and their shareholders; corporate organization and restructuring; taxation of partnerships; residence and source taxation; controlled foreign company rules; restrictions on the deduction of interest; courts dealing with tax matters; and effect of tax treaties. Several new topics—including the classification of employees and independent contractors, the taxation of pensions, patent box regimes, the taxation of indirect transfers and the tax challenges of the digital economy—have been added. Especially timely are discussions of changes stemming from the G20/OECD Base Erosion and Profit Shifting project. The introduction has also been expanded to include a new section on European Union (EU) law as it affects the tax laws of EU Member States. This new edition of a classic source of information and analysis for students, professors, researchers, tax practitioners and tax policy officials on the different ways that countries design their income tax systems will be widely welcomed by the international tax community.
Author : International Accounting Standards Committee
Publisher : Unknown
Page : 96 pages
File Size : 44,8 Mb
Release : 1998
Category : Accounting
ISBN : CORNELL:31924085208159
Author : OECD
Publisher : OECD Publishing
Page : 324 pages
File Size : 48,7 Mb
Release : 2017-03-27
Category : Electronic
ISBN : 9789264267992
This publication contains the following four parts: A model Competent Authority Agreement (CAA) for the automatic exchange of CRS information; the Common Reporting Standard; the Commentaries on the CAA and the CRS; and the CRS XML Schema User Guide.
Author : Oktavia Weidmann
Publisher : Kluwer Law International B.V.
Page : 439 pages
File Size : 48,9 Mb
Release : 2015-07-16
Category : Law
ISBN : 9789041159830
The exploding use of derivatives in the last two decades has created a major challenge for tax authorities, who had to develop appropriate derivatives taxation rules that strike a balance between allowing capital markets to function effectively by removing artificial tax barriers and at the same time protecting their countries' tax base from tax avoidance schemes that utilise these instruments. Derivatives exist in a vast variety and complexity and new forms or combinations of existing forms appear ad hoc as new risk categories emerge and companies seek to invest in or hedge these risks. This very thorough book discusses and analyses taxation issues posed by derivatives used in domestic as well as in cross-border transactions. In great detail the author presents approaches that can be adopted by tax legislators to solve these problems, clarifying her solutions with specific reference to components of the two most important domestic tax systems in relation to derivatives in Europe, those of the United Kingdom and Germany. Examples of derivatives transactions and arbitrage schemes greatly elucidate the nature of derivatives and how they can be effectively taxed. The following aspects of the subject and more are covered: – basic economic concepts in the context of derivatives such as replication, put-call-parity, hedging and leverage; - designing a suitable definition of derivatives in domestic tax law; - achieving coherence in domestic tax rules by applying a 'special regime approach' versus an 'integrative approach' and the distinction of income and capital, equity and debt; - alignment of accounting standards and taxation rules and the application of fair value accounting for tax purposes; - how to tax hedged positions and post-tax hedging schemes; - taxation of structured financial products and hybrid instruments with focus on bifurcation and integration approaches and the recent BEPS discussion drafts on hybrid mismatch arrangements; - refining the 'beneficial ownership' – concept in domestic law and in tax treaties and an analysis of recent case law; - withholding taxes in the context of domestic and cross-border dividend tax arbitrage schemes; and - tackling derivatives tax arbitrage effectively in anti-avoidance legislation. By providing an in-depth analysis of corporate taxation issues that arise in domestic as well as in cross-border derivatives transactions, this book is not only timely but of lasting value in the day-to-day work of tax lawyers and tax professionals in companies, banks and funds, and is sure to be of interest to government officials, academics and researchers involved with financial instruments taxation.
Author : Malcolm James
Publisher : Spiramus Press Ltd
Page : 488 pages
File Size : 42,6 Mb
Release : 2022-07-14
Category : Business & Economics
ISBN : 9781913507329
The Taxation of Small Businesses 2022-23 is a practical guide to all aspects of direct taxation of small businesses in one volume. It is ideal for sole practitioners and small partnerships, but will be a handy reference guide for all tax advisers. The book aims to give a clear explanation of the relevant legislation and practical advice on ways of minimising clients’ tax liabilities and warning against common pitfalls. The fourteenth edition has been updated to incorporate changes as a result of the Finance Act 2022.
Author : Malcolm James
Publisher : Spiramus Press Ltd
Page : 475 pages
File Size : 43,5 Mb
Release : 2023-08-11
Category : Law
ISBN : 9781913507473
The Taxation of Small Businesses 2023-24 is a practical guide to all aspects of direct taxation of small businesses in one volume. It is ideal for sole practitioners and small partnerships, but will be a handy reference guide for all tax advisers. The book aims to give a clear explanation of the relevant legislation and practical advice on ways of minimising clients’ tax liabilities and warning against common pitfalls. The sixteenth edition has been updated to incorporate changes as a result of the Finance Act 2023. Contents List of abbreviations Chapter 1. Income Tax Computation 1.1. Aggregation of Taxpayer’s Income 1.2. Interest 1.3. Limit on Deductions from Adjusted Net Income 1.4. Payments to Charities 1.5. Personal Allowances Deducted from Net Income 1.6. Computation of Tax 1.7. Tax Reducers 1.8. Tax Retained on Interest, Royalties and Gift Aid donations 1.9. Comprehensive Example 1.10. Death and Separation 1.11. Married Couples – Joint Property 1.12. Minor Children 1.13. High Income Child Benefit Charge Chapter 2. Taxation of Trading Income 2.1. Introduction 2.2. Statutory Definitions of Trading 2.3. Statutory Trades 2.4. Case Law 2.5. Gambling and Speculation 2.6. Illegal Activities 2.7. Individuals Trading in Shares 2.8. Definition of Trading – National Insurance 2.9. Mutual Trading 2.10. Election to Use Cash Basis 2.11. Capital and Revenue Receipts 2.12. Receipts not Received in Course of Trade 2.13. Other Receipts 2.14. Capital and Revenue Payments 2.15. Expenditure Incurred in the Course of a Trade 2.16. Duality of Purpose 2.17. Repairs and Maintenance 2.18. Replacement of Assets 2.19. Depreciation and Amortisation 2.20. Subscriptions and Donations 2.21. Sponsorship 2.22. Bad Debts 2.23. Provisions 2.24. Payments to Employees & Appropriations of Profit 2.25. Entertainment 2.26. Gifts to Customers and Samples 2.27. Gifts to Educational Establishments and Charities 2.28. Cost of Leasing Cars 2.29. Legal and Professional Fees 2.30. Fines and Payments Against the Public Interest 2.31. Interest and Bank Charges 2.32. Pre-trading Expenditure 2.33. Indirect Taxation 2.34. Compensation and ex gratia Payments to Former Employees 2.35. Redundancy Payments 2.36. Removal Expenses to New Business Premises 2.37. Premiums for Insurance 2.38. Payments to Employees for Restrictive Undertakings 2.39. Staff Training and Development 2.40. Counselling Courses in Connection with Termination of Employment 2.41. Payments to Secure Release from Unprofitable Contracts 2.42. Payments to Political Parties 2.43. Preservation of Goodwill 2.44. Payments on the Cessation of Trade 2.45. Post-cessation Expenditure 2.46. Rent 2.47. Lease Premium 2.48. Patents and Intellectual Property 2.49. Telephone 2.50. Business Rates and Council Tax 2.51. Security Expenditure 2.52. Loan Guarantee Payments 2.53. Use of Home 2.54. Website Expenditure 2.55. Expenses Connected with Foreign Trades 2.56. Valuation of Stock 2.57. Overseas Aspects of Trading Chapter 3. Capital Allowances on Plant and Machinery 3.1. Introduction 3.2. Definition of Plant and Machinery 3.3. Assets Deemed to be Plant and Machinery 3.4. Definition of Expenditure 3.5. Date of Expenditure 3.6. Disposal of Assets 3.7. Allowances 3.8. Calculation of Capital Allowances 3.9. Short-life Assets 3.10. Cessations and Successions 3.11. Hire Purchase and Leasing 3.12. Fixtures 3.13. Disposal of Fixtures 3.14. Anti-avoidance Chapter 4. Other Allowances 4.1. Business Premises Renovation Allowance 4.2. Patents 4.3. Know-how Chapter 5. Basis Periods 5.1. Current Year Basis (CYB) 5.2. Opening Year Rules 5.3. Closing Year Rules 5.4. Tax Planning on Commencement 5.5. Tax Planning on Cessation 5.6. Change of Accounting Date 5.7. Period Less than 12 Months 5.8. Period More Than 12 Months 5.9. Two Accounting Dates in Tax Year 5.10. No Accounting Date in Tax Year 5.11. Transitional Overlap Relief 5.12. Changes in Size and Nature of Operations 5.13. Death of Trader 5.14. Mergers and Demergers 5.15. Date of Commencement and Cessation 5.16. Successions 5.17. Trader Becoming, or Ceasing to be, UK Resident Chapter 6. Trading Losses 6.1. Introduction 6.2. Offset Against Future Trading Income 6.3. Transfer of Business to a Company 6.4. Offset Against Total Income and Carry-back 6.5. Offset Against Capital Gains 6.6. Losses in the Early Years of Trading 6.7. Terminal Loss Relief 6.8. Tax Planning and Loss Relief 6.9. Restriction of Loss Relief 6.10. Late Claims Chapter 7. Property Income 7.1. Introduction 7.2. Basis of Assessment 7.3. Dilapidations 7.4. Lease Premiums 7.5. Sale with Right of Conveyance 7.6. Expenditure Deductible 7.7. Sea Walls 7.8. Mutual Business 7.9. Relief for Capital Expenditure 7.10. Losses 7.11. Furnished Holiday Lettings 7.12. Rent a Room Scheme Chapter 8. Employment and Self-employment 8.1. Introduction 8.2. Benefits of Self-employment 8.3. Definition of Employment and Self-employment 8.4. Tests for Employment 8.5. Workers Supplied by Agencies 8.6. Non-executive Directors 8.7. Self-employment or a Number of Separate Employments 8.8. Provision of Services Through an Intermediary – Income Tax 8.9. Managed Service Companies 8.10. National Insurance – Deemed Employment 8.11. National Insurance – Deemed Self-employment 8.12. National Insurance – Persons Deemed not to be Employed Chapter 9. Employment Income 9.1. Income Tax – Introduction, Charging Legislation and General Definitions 9.2. National Insurance Contributions – Charging Legislation and General Definitions 9.3. Income Tax and National Insurance – a Comparison 9.4. Time of Receipt 9.5. Cash Payments to Employees 9.6. Payments Arising by Reason of Employment 9.7. Payments on Termination of Employment or Variation of Employment Terms 9.8. Damages and Compensation Paid to Employee 9.9. Sick Pay and Sickness and Other Benefits 9.10. Commission, Cashbacks and Discounts 9.11. Tax-free Lump Sum Payments 9.12. Payment of Expenses to Third Parties on Behalf of Employee 9.13. Payments for Clothing 9.14. Directorships Held by Partners 9.15. Payment of Employee’s Tax by Employer 9.16. Income Tax – Deduction of Expenses 9.17. Reimbursement of Expenses 9.18. Qualifying Travel Expenses 9.19. Entertainment 9.20. Expenses Incurred by Homeworkers 9.21. Other Deductible Expenses 9.22. Payments and Benefits Exempt from Income Tax and Class 1 National Insurance Contributions Chapter 10. Benefits in Kind 10.1. Valuation of Benefits in Kind 10.2. Benefits – Definition of Cost 10.3. Lower-paid Employment 10.4. Benefits in Kind and National Insurance Contributions 10.5. Payment of Expenses by Employer 10.6. Gift of Assets to Employees 10.7. Cash Vouchers, Non-cash Vouchers and Credit Tokens 10.8. Payment Made to a Registered Pensions Scheme for the Benefit of Two or More People 10.9. Waiver of Loan 10.10. Job-related Accommodation 10.11. Assets Available for Private Use 10.12. Expenses Connected with Living Accommodation 10.13. Cars 10.14. Fuel for Private Use 10.15. Pool Cars and Vans 10.16. Vans and Heavier Commercial Vehicles 10.17. Emergency Vehicles 10.18. Beneficial Loans 10.19. Scholarships 10.20. Relocation Packages and Guaranteed Selling Price Schemes 10.21. Medical Treatment and Medical Insurance Chapter 11. National Insurance Contributions National Insurance Contributions and Employees 11.1. Earnings Period 11.2. Aggregation of Earnings 11.3. Rate of Class 1 National Insurance Contributions 11.4. Class 1A Contributions 11.5. Calculation of Contributions 11.6. Class 1A Charge Where Benefits Provided by Third Parties 11.7. Earners over Pensionable Age 11.8. Notional Payments of Class 1 Contributions 11.9. Annual Maximum Contributions National Insurance Contributions and the Self-Employed 11.10. Class 2 Contributions 11.11. Class 4 Contributions Chapter 12. Pensions 12.1. Introduction 12.2. Scope of Regime 12.3. Registration of Pension Schemes 12.4. Payments by Registered Pension Schemes 12.5. Pension Payments 12.6. Contributions 12.7. Purchase of Shares in Sponsoring Employer 12.8. Loans to Employers 12.9. Unauthorised Payments Charge Chapter 13. Capital Gains Tax 13.1. Scope of Capital Gains Tax (CGT) 13.2. Exemptions 13.3. Residence 13.4. Capital Losses 13.5. Offset of Trading and Other Losses against Capital Gains 13.6. Capital Gains Tax Rate 13.7. Disposal Consideration 13.8. Date of Disposal 13.9. Allowable Costs 13.10. Indexation Allowance 13.11. Taper Relief 13.12. Assets Owned at 31 March 1982 13.13. Married Couples and Civil Partners 13.14. Disposal to Connected Parties 13.15. Valuation of Assets 13.16. Negligible Value Claim 13.17. Value Shifting 13.18. Disposal by Way of Security 13.19. Hire Purchase Transactions 13.20. Appropriations to and from Trading Stock 13.21. Series of Transactions 13.22. Options 13.23. Debts 13.24. Compensation 13.25. Asset Derived from another Asset 13.26. Location of Assets 13.27. Chattels and Wasting Assets 13.28. Part Disposals 13.29. Leases 13.30. Loss or Destruction of Asset 13.31. Restoration of Assets 13.32. Replacement of Business Assets 13.33. Gift Relief 13.34. Transfer of Assets to a Limited Company 13.35. Entrepreneurs’ Relief 13.36. Losses on Loans to Traders 13.37. Loan Guarantees Chapter 14. Corporation Tax 14.1. Scope of Corporation Tax 14.2. Trading income 14.3. Loan relationships 14.4. Intangible Fixed Assets 14.5. Derivative Contracts 14.6. Property income 14.7. Chargeable gains 14.8. Indexation Allowance 14.9. Indexation and Losses 14.10. Assets Owned at 31 March 1982 14.11. Assets Owned at 6 April 1965 14.12. Rollover Relief 14.13. Dividends Received 14.14. Payments to Charities 14.15. Distributions 14.16. Chargeable Accounting Periods 14.17. Computation of Tax Liability 14.18. Corporation Tax – Interaction with Income Tax 14.19. Losses and Corporation Tax 14.20. Groups and Consortia 14.21. Close Companies 14.22. Companies with Investment Business 14.23. Close Investment-holding Companies 14.24. Demergers 14.25. Purchase of Own Shares Chapter 15. Incorporation, Disincorporation and Choice of Business Medium 15.1. Introduction 15.2. Incorporation 15.3. Disincorporation 15.4. Disincorporation Relief 15.5. Choice of Business Medium 15.6. Comparison of Tax Treatment of Companies and Sole Traders 15.7. Salary vs Dividends Chapter 16. Special Classes of Taxpayers 16.1. Construction Industry Scheme 16.2. Farmers and Market Gardeners 16.3. Authors, Artists and Composers 16.4. Actors, Musicians and Entertainers 16.5. Entertainers – Other Workers 16.6. Builders 16.7. Care Providers 16.8. Barristers 16.9. Bookmakers 16.10. Breweries and Licensed Premises 16.11. Doctors and Dentists 16.12. Motor Dealers – Valuation of Used Vehicle Stocks 16.13. Fishermen 16.14. Franchising 16.15. Solicitors 16.16. Sub-postmasters 16.17. Video and DVD Traders 16.18. Clubs, Societies and other Mutual Organisations 16.19. Charities 16.20. Credit Unions 16.21. Friendly Societies 16.22. Housing Associations 16.23. Self-build Societies Chapter 17. Partnerships 17.1. Definitions 17.2. Limited Partnerships 17.3. Limited Liability Partnerships 17.4. Allocation of Profits 17.5. Assessment of Partnerships 17.6. Other Income of Partnership 17.7. Non-trading Partnerships 17.8. Post-cessation Receipts 17.9. Losses 17.10. Notional Losses 17.11. Mergers and Amalgamations 17.12. Restriction on Loss Relief for Limited and Non-Active Partners 17.13. Partnership Property Income 17.14. Corporate Partners 17.15. Partnerships and Capital Gains Tax 17.16. Roll-over and Gift Relief - LLPs Index
Author : David Southern
Publisher : Bloomsbury Publishing
Page : 269 pages
File Size : 53,9 Mb
Release : 2020-12-24
Category : Business & Economics
ISBN : 9781526507082
Brings the reader right up-to-date with the latest tax changes affecting loan relationships and derivative contracts. Taxation of Loan Relationships and Derivative Contracts - Supplement to the 10th Edition gives detailed coverage with working examples of the major legislative changes that have been introduced in these areas since the publication of the 10th edition in 2017. It contains chapters dealing with:
Author : Victor Thuronyi,Kim Brooks
Publisher : Kluwer Law International B.V.
Page : 362 pages
File Size : 53,6 Mb
Release : 2016-04-20
Category : Law
ISBN : 9789041167200
Although the details of tax law are literally endless—differing not only from jurisdiction to jurisdiction but also from day-to-day—structures and patterns exist across tax systems that can be understood with relative ease. This book, now in an updated new edition, focuses on these essential patterns. It provides an immensely useful introduction to the core common knowledge that any well-informed tax lawyer or policy maker should have about comparative tax law in our times. The busy reader will welcome the compact nature of this work, which is shorter than the first edition and can be read in a weekend if one skips footnotes. The authors elucidate the commonalities and differences across countries in areas including (much of the detail new to the second edition): • general anti-avoidance rules; • court decisions striking down tax laws as violating constitutional rules against retroactivity, unequal treatment of equals, confiscation, and undue vagueness; • statutory interpretation; • inflation adjustment rules and the allowance for corporate equity; • value added tax systems; • concepts such as “tax”, “capital gain”, “tax avoidance”, and “partnership”; • corporate-shareholder tax systems; • the relationship between tax and financial accounting; • taxation of investment income; • tax authorities’ ability to obtain and process information about taxpayers; and • systems of appeals from tax assessments. The information and analysis pull together valuable material which is scattered over a disparate literature, much of it not available in English. Especially considering the dynamic nature of tax law, whose rate of change exceeds that of any other field of law, the authors’ clear identification of the underlying patterns and fundamental structures that all tax systems have in common—as well as where the differences lie—guides the reader and offers resources for further research.
