Asset-backed contributions meaning

In this issue: Companies and corporation tax Employment taxes International Real estate tax Anti-avoidance Taxes management and litigation Daily and weekly news alerts New and updated content Dates for your diary Trackers Useful information Companies and corporation tax Supreme Court confirms Court of Appeal ruling: UK-Canada DTT conferred no UK taxing rights over the assigned payments (Royal Bank of Canada v HMRC) As outlined below, in Royal Bank of Canada [2025] UKSC 2, the Supreme Court rejected HMRC’s appeal and agreed with the Court of Appeal that Article 6 of the UK-Canada double tax treaty (DTT)—which grants taxing rights to the jurisdiction where the immovable property is located, in this instance an oil field—did not apply to the payments. The reason was that the right to exploit the UK oil field was held by Sulpetro (UK). The parent of Sulpetro (UK) (at first, Sulpetro and later BP after acquiring Sulpetro’s rights) only...

In this issue: Private equity and venture capital 2025–26 — Fiscal events, including the Budget Taxes management and litigation Companies and corporation tax Employment taxes Individuals and income tax Share and asset sales VAT Daily and weekly news alerts New and updated content Dates for your diary Trackers Useful information Private equity and venture capital Government issues response to consultation on tax treatment of carried interest Following its consultation on the taxation of carried interest—examining in particular the qualifying conditions for a new regime within the income tax framework and aiming to ensure the treatment most appropriately reflects economic reality—the Government has confirmed plans to introduce that regime from April 2026. The provisions will be set out in Finance Bill 2026, with draft legislation expected before the Parliamentary summer recess (normally mid to late July). Carried interest will be treated as trading profits and will fall within income tax and...

In this issue: Probate Trusts Court of Protection Elderly and vulnerable clients UK taxes for Private Client Tax avoidance, evasion and non-compliance Contentious trusts and estates Pensions, insurance and tax efficient investments Scotland, Wales and Northern Ireland International Question of the week Additional Private Client updates this week Daily and weekly news alerts LexTalk®Private Client: a Lexis+® community New and updated content Dates for your diary Trackers Latest Q&A Useful information Probate High Court upholds the will and dismisses the counterclaim due to laches and lack of merit (Stephenson (as Executors and Beneficiaries of the estate of Malcom Roocroft (deceased)) v Daley) The Chancery Division granted the claimants probate in solemn form of the deceased’s final will, and rejected the defendants’ counterclaim which aimed to set the will aside for want of knowledge and approval. The court concluded the deceased understood and endorsed the...

THIS PRACTICE NOTE RELATES TO REGISTERED OCCUPATIONAL PENSION SCHEMES STOP PRESS 1: On 18 November 2025, the Pensions Regulator (TPR) urged trustees to treat member data as their foremost ‘strategic asset’ so schemes are prepared for pensions dashboards by the final connection date of 31 October 2026. After engaging with hundreds of schemes, TPR noted improvements in data quality but pointed to gaps in value data and excessive reliance on administrators, warning that neglect could put dashboard compliance at risk. It also issued refreshed member data guidance that brings together all existing data-related guidance, sets out clearer expectations for trustees and shares best practice to strengthen data management capability. TPR adds that it is reviewing data readiness among the UK’s largest schemes and will step up engagement in 2026. For more information, see LNB News 18/11/2025 43. STOP PRESS 2: On 19 November 2025, the Pensions Administration Standards Association (PASA) released guidance, ‘The Six Data Quality Dimensions for Pension Scheme Member Data’, together with a supporting...

What is a long-term incentive plan? As set out in the Practice Note: What is a long-term incentive plan?, the awards most frequently delivered under a long-term incentive plan (LTIP) typically comprise: conditional share awards (often referred to in the US as restricted stock units (RSUs)) nil-cost options share appreciation rights (SARs) forfeitable shares, sometimes described as restricted stock A brief summary outline of the likely capital gains tax (CGT) treatment on disposals of shares obtained on the vesting of each LTIP award type is set out below. For more detail and background on the different award types available under an LTIP, see Practice Note: Structure of a long-term incentive plan—Types of awards for further guidance. Please note that this Practice Note proceeds on the basis that, at acquisition of the shares or otherwise on vesting of the LTIP awards, the employee has been fully subject to income tax and, where the shares are readily convertible, national insurance...

With appreciation to other contributors from Squire Patton Boggs offices across its global network. Cross-border JVs There is no single, universal approach to structuring cross-border joint ventures (JVs) (ie where one or more JV participants are based outside the UK and intend to establish a JV outside the UK). The provisions of any contract must ultimately set out the parties’ commercial arrangement. However, many of the legal points highlighted in this and the related Practice Notes: Cross-border joint ventures—initial considerations, Cross-border joint ventures—management and control, and Cross-border joint ventures—termination may influence the choice of jurisdiction for the JV vehicle, as well as the commercial bargain itself, and should therefore be assessed as early as possible to give the JV the best chance of success. Even if a joint venture agreement (JVA) uses a familiar governing law, such as English law, creating a cross-border JV can produce unexpected and unfamiliar issues. Each issue is covered at a relatively high level, but definitive local legal advice should always be taken...

Introduction I, [ insert debtor's name ], invite my creditors to consider an individual voluntary arrangement (IVA). From the attached estimated statement of affairs, it is apparent I am insolvent: I cannot pay my debts as they fall due, and my liabilities outweigh my assets. I face two options—either petition for my own bankruptcy or propose an IVA to my creditors. I first reviewed my position with my Nominee, [ insert nominee's name ], on [ insert date of meeting ], who advised that I obtain independent insolvency advice. My Nominee has explained all available debt resolution processes; having reflected on that advice, I believe an IVA would benefit both my creditors and me. I outline below why an IVA would be advantageous: The total funds achievable through the IVA are higher than those likely in my bankruptcy. The costs of administering the IVA are lower than those that would arise in my bankruptcy...

Note: these due diligence questions are prepared for the buyer and are broadly framed. Not every question will be pertinent to each pension scheme. In practice, they should be tailored as required to reflect the circumstances of the specific transaction (and relevant pension schemes). Note: the meanings of ‘Business’ and ‘Seller’ in this questionnaire are intended to mirror the definitions in the sale and purchase agreement for the business the buyer is acquiring. In an asset sale, the buyer will not usually take on the seller’s pension scheme. 1 Pensions 1.1 Please list: (a) all pension schemes to which the Seller is currently paying contributions (or would be but for a contributions holiday) or in which the Seller participates; (b) all life assurance schemes and/or other comparable protection schemes; (c) any former pension schemes of the Seller that applied before the existing schemes...

State Aid: The Basics Guide The Department for Business, Innovation & Skills’ July 2015 guide, State Aid: The Basics Guide, explains that state aid arises wherever public resources are used to give organisations an edge over others, potentially distorting competition and harming consumers and businesses across the EU. The concept is deliberately wide, as an “advantage” can be delivered in many ways, for example: grants loans tax breaks the use or sale of a state asset free of charge or for less than market value Public authorities, including local authorities in England and Wales, are accountable for ensuring their policies and projects comply with these requirements. During the implementation period following Brexit, state aid rules continue to apply in the UK. The annex to the Department for Education’s November 2019 publication, Securing Developer Contributions for Education, notes that unlawful state aid can occur in relation to developer contributions towards education...