Authors: Richard Bramwell, QC; John Lindsay; Alun James; Julian Hickey; Michael Collins



Taxation of Companies and Company Reconstructions covers the 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.

Presented in a logical and structured manner, this title examines each subject area thoroughly, starting with the basic principles, before expounding on the finer details and practical application.

The author team, who are all practicing tax advisers at a leading solicitors’ firm or barristers’ chambers, update the title three times a year, providing insight into the latest developments in corporation tax law, in-depth technical analysis and comprehensive problem-solving advice. Their commentary includes coverage of relevant passages in the HMRC manuals, and professional analyses of case law and corporate tax legislation.

EXPERT ANALYSIS AND PRACTICAL APPLICATION OF CORPORATE TAX LAW

Now in its 9th edition, Taxation of Companies and Company Reconstructions continues to help readers navigate the sometimes frequent and complex changes in UK tax law. This invaluable resource offers an unparalleled combination of practical advice, technical analysis, expert commentary, and statutory interpretation, making it a vital addition to any corporate tax adviser’s library.

Volume 1 focuses on:

• Introductory and general corporation tax topics (including relief for losses, accounts in foreign currency, disincorporation relief and the GAAR)
• Compliance and litigation
• Close companies
• Distributions and Purchases of Own Shares

Volume 2 deals with:

• Intangible fixed assets
• Derivatives
• Transfer pricing
• Loan relationships
• Repos and stock loans
• Structured finance arrangements
• Transfers of income streams
• Shares accounted for as liabilities
• Disguised interest
• Corporate interest restriction
• Hybrid and other mismatches legislation
• Diverted profits tax
• Digital services tax

Volume 3 covers:

• Non-resident companies (including the extension of corporation tax to non-resident companies carrying on a UK property business)
• Controlled foreign companies
• Double tax relief
• EU law
• Group relief
• Intra-group transfer relief for CGT, SDLT, and Stamp Duty
• Reconstructions, and the Transactions in Securities rules

These three volumes combined cover:

• Key aspects of company taxation law
• How tax provisions apply in practice
• How best to arrange asset transfers for company reconstructions
• Coverage of the reliefs available for corporate reconstructions
• Guidance on distributions, overseas matters, groups and reconstructions
• An explanation of the rules of loan relationships and withholding tax, derivatives contracts legislation and intangible fixed assets legislation
• In-depth technical analysis with an authoritative discussion on points of statutory interpretation
• Helpful guidance and analysis of case law and legislation on company taxation
• Practical, problem-solving advice to show exactly how provisions apply in practice, with worked examples
• Analysis of key cases