De minimis exception meaning

Mergers The CMA has released the complete wording of its phase 1 clearance ruling, confirming clearance under the de minimis exception for proposed purchase by Keysight Technologies, Inc...

Mergers The CMA authorised, under the de minimis exception, planned acquisition by Keysight Technologies, Inc...

General principles The trustees are, for tax purposes, regarded collectively as a single person, distinct from the individuals who serve as trustees from time to time. An interest in possession (IIP) means a beneficiary has an immediate right to the trust income as it arises. That income belongs to the beneficiary, and the trustees lack authority to retain it, save to meet proper expenses. Where trust income does not fall within the definition of accumulated or discretionary income in section 480 of the Income Tax Act 2007 (ITA 2007), it is treated as the income of ‘other persons’ and taxed at the basic and dividend rates. Ultimately, the income is assessed on the beneficiary at their personal rates, irrespective of when, and even whether, it is actually paid to them. Nevertheless, the trustees are liable to income tax on income arising from trust property because they are the legal owners of that property and thus the persons who receive the income. The way IIP and discretionary trusts are differentiated...

Investment trust An investment trust is a collective investment vehicle structured as a listed, UK tax-resident public limited company. Despite the label, in legal terms an investment trust is a company rather than a trust. The expression stems from a period when these vehicles were established as trusts, but they later converted to limited companies and therefore are no longer trusts in any legal sense. Where HMRC grants approval to an investment trust, it can access certain UK tax advantages. This Practice Note sets out the eligibility criteria that must be met for a fund to obtain approval as an investment trust for UK tax purposes. It also addresses the continuing requirements that must be satisfied in every accounting period for which the vehicle holds that approval...

The corporate interest restriction (CIR) rules are extensive and technically demanding. This Practice Note serves as a primer to the CIR and points readers to further detail in related materials: Practice Note: Corporate interest restriction—glossary of key terms, explaining key expressions and concepts used across the legislation Practice Note: Corporate interest restriction—the main rules, providing an in‑depth overview of the core operative provisions Practice Note: Corporate interest restriction—administration, covering procedural matters, including the interest restriction return Practice Note: Corporate interest restriction—elections, outlining the various elections a group may include in its interest restriction return The regime has applied since 1 April 2017. The principal provisions appear in Part 10 of the Taxation (International and Other Provisions) Act 2010 (TIOPA 2010), with associated administrative rules in TIOPA 2010, Sch 7A. HMRC guidance is set out in the Corporate Finance Manual, beginning at CFM95000. Background to the CIR As an element of the G20/OECD initiative addressing Base Erosion and Profit Shifting...