total return swap over shares in subsidiary

Abnormal pay practices

Accrued income scheme

Acquisition of convertible securities

Agreement between taxpayer and Revenue

Annual interest payment

Application of other regimes to apprenticeship levy


Arbitrage schemes

Arrangement involving grant of put and call options

Companies owned by family trusts



Meaning of

Artificial arrangements

Artificial transactions in land

– see also Transactions in land

Arrangement or scheme


Associated persons, transactions between dealing company and associated company

Assured tenancy allowances

Award of redeemable shares in special purpose offshore company

Bank payroll tax

Banking bonuses in form of restricted securities

Bed and breakfasting

Beneficial loan treatment

Branch exemption regime

Buying capital allowances

Buying losses and gains

Cancellation of tax advantage from transactions in securities

Capital gains tax

Acquisition of Capital Redemption Policies

Disposal of shares

Exchange of shares for loan stock

Flip-flop scheme

Pre-ordained series of transactions

Capital losses

Capital sums for leases

Capital sums paid to settlor


Change in company ownership

Charge to tax

Chargeable gains, allowable losses

Charitable donations


– see Charities



Professional negligence

Close company participators


Companies buying losses and gains

Companies generally

Conditions for

Connected persons

Asset, use of

Consideration received by

Controlled foreign companies

Corporation tax, company purchase scheme

Counteracting effect of avoidance arrangements

Counteraction of avoidance arrangements

Counteraction procedure

Final notice

Proposed notice

Debt capping

December 2014 changes

Deep discount on redemption of securities

Deferment of SDLT

Definition of relevant discounted securities

Derivative contracts


Disclosure (DOTAS)

Disclosure obligations on promoters of schemes and arrangements

Disclosure of avoidance schemes

Disclosure of tax avoidance schemes

Discounted options scheme, employee benefit trusts

Disposal of equipment on lease

Dividend payments to employees through employee trust

Dividends (not usually caught)

Divorce, court order for financial provision

Double taxation relief

Claims or elections

Counteraction notices

Deemed foreign tax, schemes involving

Effect of paying foreign tax

Enabling attribution of foreign tax

Inflating credit for foreign tax

Reducing a person's tax liability

Shifting foreign tax from one source of income to another

Tax-adjusted carrying value

Tax-deductible payments

Underlying-tax scheme or arrangement, main purpose of

Dredging allowances

EC mergers directive

Effect of drafting error

Effect of Ramsay principle on meaning of market value in TCGA 1992, s. 116

Employee benefit trusts

Employees, PAYE and NICs

Employment income provided through third parties


Employment losses

Allowable capital losses


Employment-related liabilities

Enhanced capital allowances

Enterprise investment scheme deferral of capital gains

Enterprise zones

Exemption for sales of going concern

Failed fiscal minimisation scheme

Failed income tax deduction

Farmers and market gardeners herd basis election

Film schemes

Finance leases

Finance leases and loans

Finance leasing

Friendly societies life or endowment business

Furniss v Dawson approach

General anti-abuse rule

General Anti-Abuse Rule (GAAR)


Gift aid

Green technologies

Groups of companies

Group relief, unallowable overseas losses

Pre-entry gains and losses

Herd basis

History of

HMRC entitled to issue discovery assessment under TMA 1970, s. 29

HMRC information powers

Holiday for new businesses

Implementation of scheme flawed, dishonesty

Incorporation relief

Information and inspection powers

Information powers

Inheritance tax

Conditionally exempt transfers

Excluded property

Government securities in foreign ownership

Potentially exempt transfer

Reverter to settlor, Ramsay principle

Settled property

Insurance companies, transfers of long-term business

Insurance policy transactions, tax avoidance scheme

Intangible fixed assets

Integral features

Inter-group transactions

Interest and royalty payments, exemption from tax

Interest rate and currency contracts and options

Interest relief restriction, non-active partners

– see Partnerships

International leasing


Intra-group relief

Isle of Man scheme, double taxation relief

Lease premiums

Leased assets

Leasing plant and machinery

Loan agreement

Value of shares issued not constitute income of lender for tax purposes

Loan finance arrangements

Loan notes converted to qualifying corporate bonds by deed of variation

Loan or credit transactions

Loan relationships

Long-life assets

Loss relief restriction, partnerships

– see Partnerships

Loss reliefs

Machinery and plant allowances

Adjustments of assessments etc.

Connected persons

Exception for manufacturers and suppliers

Finance leases and certain operating leases

Hire-purchase etc.

Long-life assets

Relevant transactions, sale, hire-purchase and assignment etc.

Sale and finance leasebacks

Sale and leaseback etc.

Transactions to obtain allowances/tax advantage

Transfers of interests in oil fields

Value added tax liabilities and rebates

Managed service companies

Management expenses

Manufactured payments

Mineral extraction allowances

Mining and oil activities, decommissioning costs

Multiple same-day settlements

New Zealand

Assignment by partner of rights under partnership agreement

Financing production of feature films, meaning of arrangement

Non-commercial changes in value

Offshore funds

Optional remuneration arrangements (OpRA)

Parental settlements


Partnerships, trading losses

Patent allowances

Patents, reduced corporation tax rate


– see PAYE


Payment of discretionary bonuses to a remuneration trust structure

Payments in kind


Penalties for enablers of defeated arrangements

Penalties in connection with offshore matters

Pension schemes

Lump sums

Personal service companies

Personal service companies (IR35 rules)


Public sector

Summary of current rules

Petroleum revenue tax

Tariff receipts

Uplift, contractor financing

Plant and machinery allowances

Annual investment allowance

Assets received as a gift

Buyer's allowances, restrictions on

Buyer's expenditure

Buyer's manufacturers and suppliers, exception for

Capital allowances, deduction transfer and profit transfer

Connected persons

Election for revised qualifying expenditure in sale and leaseback cases

Finance leasing

First-year allowances



Latent capital allowances

Leased plant and machinery

Lessor not bearing non-compliance risk


Qualifying expenditure, restriction on

Relevant transactions

Restrictions on allowances

Sale and finance leasebacks

Targeted loss buying

Tax advantage, transactions to obtain

Transfer followed by hire purchase, restriction on hirer's costs

Transfer of an entitlement to benefit

Writing-down allowances, restrictions on

Post-acquisition changes to shares

Power to vary stamp duties

Practices avoiding or reducing liability

Pre-entry gains and losses

Private residence relief


Production of documents, legal professional privilege

Profit and loss shifting to avoid or reduce surcharge liability

Profit-related pay, manipulation of profit periods

Promoter rules

Conduct notice

Monitoring notice

Stop notice

Property income

Corporation tax

Qualifying change

Property traders

Qualifying non-UK pension schemes

Ramsay principle

– see also Ramsay principle


Reducing the value of leased assets to the lessor


Abnormal pay practices


Practices avoiding or reducing liability


Abnormal increases

Assignments treated as grants

Repayment of surplus advance corporation tax


Reverse premiums

Salary sacrifice arrangements

Sale and lease back of land

Sale and lease-back, requirement

Sale and re-conveyance

Sale and repurchase of securities (repos)

Sales of occupation income

Sales treated as being for an alternative amount


Second-hand life insurance policies

Securities-based remuneration

Series of transactions

Commercial purpose


One scheme


Ramsay principle


Allotment of shares to shareholders' wives


Settlor-interested trusts


Shares in qualifying company

Sideways loss relief

Special rate cars

Stamp duty

HMRC practice

Ramsay principle

Statutory provisions

Stamp duty land tax


Incidental transactions

Linked transactions

Stamp duty reserve tax

Inapplicability of GAAR

Ramsay principle


Stamp duty, fraudulent misrepresentation

Structured finance arrangements

Substantial shareholding exemption

Tainted charitable donations

Taper relief

Tax advantages

Counteraction of


Meaning of

Tax arbitrage

Tax credits, arrangements to pass on value of

Tax-avoidance arrangements

Third party payments of money/transfer of assets

Timing of capital expenditure

Tonnage tax

Trade loss relief

Trading losses



– see Partnerships

Trading stock, transfers within group

Transactions associated with loans or credit

Transactions in certificates of deposit

Transactions in land

Transactions in land, direction for deduction of tax from payments to non-residents

Transactions in securities

Transactions in securities, cancellation of tax advantage

Transfer of allowances on change of ownership

Transfer of assets abroad

Transfer of business to a company

Transfer of deductions

Transfer of income streams

Transfer of non-UK trade

Transfer of overseas securities and payment of manufactured overseas dividend, relevant statutory provisions construed

Transfer of property for advantage, extra-statutory concession D2

Transfer of securities with/without accrued interest

Transfer of UK trade

Transfer pricing

Transfers of partnership interests

Transition in Scotland to the Land and Buildings Transaction Tax

Unapproved share schemes

Use of self-employed labour

Value added tax

Value shifting

Value shifting, agricultural properties