Stop press: The Data (Use and Access) Act 2025 (Commencement No 6 and Transitional and Saving Provisions) Regulations 2026, SI 2026/82 now activate the outstanding parts of the Data (Use and Access) Act 2025 (DUAA 2025). Measures covering subject access requests, legitimate interests, purpose limitation, automated decision-making, cross-border transfers and enforcement take effect from 5 February 2026, while those on penalty notices and complaints apply from 19 June 2026. For further detail, refer to Practice Note: Data (Use and Access) Act 2025—employment implications. This Precedent will shortly be revised to reflect these developments. [to be printed on employer letterhead] [ Name of Employee ][ Address ][ Date ] Dear [ insert employee's name ] Secondment to [ insert name of host company ] Following our recent conversations, I am writing to confirm the arrangements we have agreed for your secondment to [ insert name of host company ] (the
[ Insert name and address of client ] [ insert date ] Dear [ insert name of contact at the client ] Explaining the disclosure process and your obligations Thank you for instructing us in relation to [ insert matter name / details ]. [ This letter accompanies our retainer OR Our retainer will follow under separate cover ]. It [ has been confirmed OR is likely OR is possible ] that your dispute with [ describe other parties ] will be determined in the Business and Property Courts [ if it proceeds to formal litigation ]. This letter explains what disclosure under the Disclosure Scheme ( DS ) in the Business and Property Courts involves, and what you must know about the procedure. The DS seeks a fundamental cultural shift in the approach to disclosure in civil litigation. So, even if you have handled
This Agreement is entered into on [ insert date ] between: 1 [ insert name of manufacturer ] [ of OR a company incorporated in [ England and Wales ] under number [ insert registered number ] whose registered office is at ] [ insert address ] (Manufacturer); and 2 [ insert name of customer ] [ of OR a company incorporated in [ England and Wales ] under number [ insert registered number ] whose registered office is at ] [ insert address ] (Customer). Each of the Manufacturer and the Customer is a party and, together, the Manufacturer and the Customer constitute the parties... Background: (A) The Manufacturer manufactures [ insert ]... (B) The Customer Group manages the distribution and sale of [ insert ]... (C) The Manufacturer intends to manufacture and sell the Product to the
This Deed is dated on [ insert day and month ] 20[ insert year ] Parties [ Insert name of Chargor ], being a company incorporated in England and Wales, bearing registered number [ insert company number ], and whose registered office is situate at [ insert address ] (the Chargor); and [ Insert name of Lender ] of [ insert address ] (the Lender). Recitals The Lender makes facilities available to the Chargor under various financing arrangements. It is a condition of the Lender making the facilities available to the Chargor that the Chargor enter into this Deed in favour of the Lender. ...
FORTHCOMING CHANGE: Following a 2020 call for evidence and a 2021 response, and after review by the relevant HMRC–industry working group plus a 2023 consultation, the government stated in a consultation outcome on 28 April 2025 that, from 2027, it plans to replace stamp duty and SDRT with a single self-assessed stamp tax on securities, broadly reflecting the proposals in the 2023 consultation document. Budget 2025, announced on 26 November 2025, also confirmed that this unified tax—called the Securities Transfer Charge—will be self-assessed and paid (and reported) via a new online portal. For more details, see: News Analyses: Tax update spring 2025— Stamp taxes on shares modernisation Tax update spring 2025— Tax analysis— Stamp and transfer taxes TAMD 2023— Stamp taxes on shares modernisation TAMD...
This Agreement is made on [ insert date ] Parties [ Insert Employer’s name ], whose registered office is at [ insert Employer’s address ], company registration number [ insert Employer’s company number ] ( Employer); [ Insert Employee’s name ] of [ insert Employee’s address ] (you). The parties agree: Termination of employment 1.1 Your employment with the Employer [ will terminate OR terminated ] owing to [ insert reason for termination ] on [ insert date ] ( Termination Date). 1.2 For the period up to and including the Termination Date, you [ will be OR have been ] paid your accrued basic salary (less deductions for income tax and primary class 1 (employee) National Insurance contributions ( PAYE Deductions )) and [ will have OR have ] received your contractual benefits [ , including a payment of £[ insert amount ] in...
[ Team Leader ] [ insert HMRC address ] [ insert date ] Application seeking advance clearance under section 1091 of the Corporation Tax Act 2010 [and sections 138 and 139(5) of the Taxation of Chargeable Gains Act 1992] 1 Introduction We act on behalf of [ insert name of the target company ] ( Company A) [ and for the shareholders of Company A ]. Company A qualifies as the ‘distributing company’ for the purposes of section 1079 of the Corporation Tax Act 2010 ( CTA 2010). [ In connection with the proposed arrangements outlined in this letter, we request confirmation under CTA 2010, s 1091 that the distribution described herein will be treated as an exempt distribution within the meaning of CTA 2010, s 1075 ]......
FORTHCOMING CHANGE: On 26 November 2025, within Budget 2025, it was confirmed that from April 2029, only the first £2,000 per year of any pension payment made under a salary sacrifice arrangement will be exempt from National Insurance contributions ( NICs). Employee sums put through salary sacrifice above £2,000 a year will attract both employer and employee NICs, so any amount over £2,000 will, for NICs, be treated in the same way as other employee workplace pension contributions. Employer contributions remain unchanged, and income tax relief is unaffected. Employers will be required to report the total amount of salary sacrificed via existing payroll software, with HMRC committing to engage with stakeholders......
FORTHCOMING CHANGE: On 26 November 2025, within Budget 2025, the government confirmed that, from April 2029 onwards, only the initial £2,000 per year in total of any pension payment under a salary sacrifice scheme arrangement will escape National Insurance contributions ( NICs). Amounts employees sacrifice beyond £2,000 annually will attract both employer and employee NICs, meaning any sum over that limit will, for NICs purposes, be handled in the same way as standard employee workplace pension payments. Employer pension contributions are unchanged, and income tax relief also remains intact. Businesses must record the aggregate salary given up using their existing payroll software systems, and HMRC has pledged to consult and engage stakeholders, as required. Further HMRC guidance will be published ‘before April 2029’......
FORTHCOMING CHANGE: On 26 November 2025, within Budget 2025, it was confirmed that, from April 2029, only the first £2,000 each year of pension savings made under a salary sacrifice arrangement will escape National Insurance contributions ( NICs). Any amount an employee sacrifices above £2,000 per annum will attract both employer and employee NICs, meaning the surplus over £2,000 will, for NICs, be handled in the same manner as other staff workplace pension contributions. Employer-paid contributions are not altered by this measure, and income tax relief continues as before, as announced in Budget 2025 officially......
FORTHCOMING CHANGE: On 26 November 2025, within Budget 2025, the government confirmed that from April 2029, only the first £2,000 per year of pension saving made under a salary sacrifice arrangement will be exempt from National Insurance contributions ( NICs). Employee sums channelled through salary sacrifice above £2,000 a year will attract both employer and employee NICs, with the effect that any portion exceeding £2,000 will be treated for NICs in the same manner as other employee workplace pension contributions. Employer contributions remain unchanged, and income tax relief is unaffected. Employers will be required to report the total salary sacrificed through existing payroll software, and HMRC has pledged to engage with stakeholders across the sector. HMRC will issue further guidance ‘before April 2029’. The National Insurance Contributions ( Employer Pensions Contributions) Bill 2026 will introduce a new subsection into section 4 of the Social...
FORTHCOMING CHANGE On 26 November 2025, as part of Budget 2025, it was confirmed that from April 2029 only the first £2,000 per year of pension contributions made via a salary sacrifice arrangement will be exempt from National Insurance contributions ( NICs). Any employee contributions sacrificed above £2,000 a year will attract both employer and employee NICs, meaning the portion exceeding £2,000 will, for NICs purposes, be handled in the same way as other employee workplace pension contributions. Employer contributions are unchanged, and income tax relief remains in place......
FORTHCOMING CHANGE: On 26 November 2025, as part of Budget 2025, it was confirmed that from April 2029, only the first £2,000 in each year of pension saving arranged via salary sacrifice will be exempt from National Insurance contributions ( NICs). Any employee amounts channelled through salary sacrifice above £2,000 annually will attract both employer and employee NICs, meaning any sum beyond £2,000 will, for NICs, be handled in the same manner as other staff workplace pension payments. Employer contributions remain unchanged, and income tax relief is also preserved. Employers must report the value of salary surrendered using existing payroll systems, with HMRC pledging to consult stakeholders. HMRC intends to issue additional guidance ‘before April 2029’, ahead of the April 2029 start date......
[send by email to the address shown in HMRC manual CTM34195] [ Date ] Dear [ insert organisation name ] Notification of intention to migrate — [ Company name, address, place of incorporation, tax district and unique taxpayer reference ] 1 Background to notification and our authority to act as agent 1.1 Acting for our client, [ company name ] (the Company), and pursuant to section 109B of the Taxes Management Act ( TMA) 1970, we notify HMRC that the Company proposes to become non‑ UK resident and request approval for arrangements to settle the Company’s tax liabilities. 1.2 The Company plans to migrate from the UK with effect from [ insert date of migration ] (the ‘ Migration Date’). 1.3 The Company has authorised us to act on its behalf in respect of this notification and associated approval request. Enclosed at Appendix 1 is the Company’s [ signed...
This Loan Note Instrument is entered into on [ insert day and month ] 20[ insert year ] by 1 [ insert name of offeror ], a company incorporated in England and Wales under number [ insert company number ], whose registered office is at [ insert address ] (the Company). Background ( A) To support a takeover offer for [ offeree PLC ] (the Offeree), the Company invited shareholders of the Offeree to elect to receive loan notes issued by the Company as an alternative to receiving [ cash AND/ OR [ and ] new Company shares ] as consideration for the disposal of their shares in the Offeree to the Company (the Loan Note Alternative). ( B) The terms of the offer are set out in [ an offer document OR a scheme document ] issued by the Company on [ date ] 20[ year ] (the [...
FORTHCOMING CHANGE relating to the modernisation of stamp taxes on shares framework : In 2027, stamp duty and SDRT will be superseded by a single, self-assessed securities tax—the securities transfer charge ( STC)—to be paid and reported through a new online portal. Broadly, the STC is expected to reflect the proposals consulted on in 2023. Finance Bill 2026 ( FB 2026) provides a power, effective from Royal Assent, to make secondary legislation enabling taxpayers to trial the digital service, self-assess their stamp taxes on securities liabilities, and submit transaction details electronically. For more on the modernisation of stamp taxes on securities, see News Analyses: Budget 2025— Tax analysis— Stamp and transfer taxes, Tax update spring 2025— Stamp taxes on shares modernisation, Tax update spring 2025— Tax analysis— Stamp and transfer taxes, TAMD 2023— Stamp taxes on shares...
1 Deductions from payments and indemnity for tax deductions 1.1 [ Subject to any contrary provision in this Agreement, ] the Company will pay the Shareholders [ all amounts due under this Agreement ] free from deductions of any kind or any withholdings, except to the extent required by applicable law......
1 Definitions and interpretation 1.1 In this Agreement, and except where the context dictates otherwise, the expressions below shall bear the meanings set out here: Relevant Proportion means, for the purpose of clause, the greatest share of the Company’s [ trading ] losses [ and other amounts eligible for relief from taxation ] that the law permits to be surrendered to the relevant Shareholder (or a member of its Shareholder Group), or, as applicable, the greatest share of the Company’s trading profits against which the Shareholder (or a member of its Shareholder Group) is permitted by law to surrender its [ trading ] losses [ and other amounts eligible for relief from taxation ] ; VAT means United Kingdom value added tax [ and any other tax imposed in substitution for it OR , any other tax imposed in...
TC/[ insert year ]/[ insert case number ] In the First-tier Tribunal ( Tax Chamber) Between: [ Name of appellant ] Appellant and The commissioners for her majesty’s revenue & customs Respondents Bundle one: documents Tab Description Date Page Tribunal papers Tab 1 — Notice of appeal to Tribunal [ insert date ] [ insert page number ] Tab 2 — [ Appellant’s grounds of appeal [only include......
[ Law firm’s letterhead ] [ Addressed to client ] Acquisition by [ name of buyer ] (the Buyer) of [ name of target company ] (the Company) from [ name of seller ] (the Seller)—tax [ deed of ] covenant and tax warranties I enclose, for your consideration, an initial draft of the tax covenant and the tax warranties. In a purchase of a private limited company, it is customary for the buyer to receive protection under both a tax covenant and tax warranties. A short outline is set out below of: the purpose of the tax covenant and the tax warranties particular procedural matters addressed by the tax covenant, and a list of specific queries on which I would appreciate your instructions 1 The tax covenant The tax covenant determines how responsibility is shared between the Seller and the Buyer for tax...
HM Revenue & Customs [ insert appropriate HMRC team ] [ insert relevant HMRC address ] Contact by email directly at: nonstatutoryclearanceteam.hmrc@hmrc.gov.uk [ Commercially sensitive information ] Dear [ insert organisation name ] Clearance service: non-statutory clearance application—[ insert type of tax legislation which is the subject of the clearance application ] and its application to [ a ] transaction [ s ] involving [ name of company ] (the Company) 1 Information about the applicant and our authority to act as agent We represent [ insert name of the company ] (the Company), a body incorporated in [ insert place of incorporation ] on [ insert date of incorporation ], holding the company registration number [ insert company number ], with its registered office situated at [ insert address ]. The Company’s [ corporation tax reference OR PAYE reference OR VAT registration ] number is [ insert the...
Loan note instrument—private M& A—share purchase This Instrument is made on [ insert date ] 20[ insert year ] Parties [ Insert name of issuing company ], a company incorporated in England and Wales with number [ insert company number ], having its registered office at [ insert address ] ( Issuer ) Background The Issuer has decided to issue, in an aggregate nominal amount not exceeding £[ insert value ], [ insert rate ]% [ subordinated ] redeemable loan notes, which shall be constituted in accordance with this document......
[ Team Leader ][ insert HMRC address ][ insert date ] Application seeking advance clearances under [section[s] 138[ and 139(5)] Taxation of Chargeable Gains Act 1992][ and ][section 701 Income Tax Act 2007[ and section 748 Corporation Tax Act 2010]] 1 Introduction 1.1 We represent [ insert name of the target company ] ( Company A ) [ and also the shareholders of Company A ]. This letter relates to the proposed steps outlined below (the Transactions) and requests confirmation under: 1.1.1 [ section 138 Taxation of Chargeable Gains Act 1992 ( TCGA 1992 ) that section 137 TCGA 1992 will not be applicable; ] 1.1.2 [ section 139(5) TCGA 1992 that that subsection is not to apply; ] 1.1.3 [ section 701 Income Tax Act 2007 ( ITA 2007 ) that a counteraction notice should not be issued under section 698 ITA 2007; and ] ...
HM Revenue and Customs [ insert address ] [ insert date ] Election under section 171A(4) of the Taxation of Chargeable Gains Act 1992 Acting together, [ insert name of the company to which the chargeable gain or allowable loss has accrued ] ( Company A) and [ insert name of company to which the chargeable gain or allowable loss is to be transferred ] ( Company B) submit this election pursuant to section 171A(4) of the Taxation of Chargeable Gains Act 1992 ( TCGA 1992)......
When evaluating a general damages claim, the practitioner ought initially to refer to the Judicial College Guidelines (JCG)...
This Practice Note This Practice Note reviews mechanisms used in settling litigation. A Tomlin order consists of a consent order paired with a schedule. It operates to stay proceedings on terms that have been agreed. The provisions contained in the schedule may remain confidential. This Practice Note describes the scope of confidentiality attaching to the schedule and sets out how it differs from a standard consent order. Sample wording for a Tomlin order is included, alongside links to precedents, as well as guidance on court approval. It also addresses varying, setting aside and enforcing a Tomlin order, including the considerations the court will take into account when handling applications for each. Further guidance is provided on interpreting and applying the relevant provisions of the CPR; however, some courts and divisions impose very specific requirements for both drafting and approval, and for approaching the schedule and confidentiality issues. Accordingly, you must consider the particular rules and court guide provisions in the forum where your claim is proceeding when drawing up the Tomlin order...
Date [ date ] Parties [ name of Landlord ] [ of OR incorporated in England and Wales (company registration number [ number ]) with its registered office at ] [ address ] (Landlord) [ name of Tenant ] [ of OR incorporated in England and Wales (company registration number [ number ]) with its registered office at ] [ address ] (Tenant) [ [ name of Guarantor ] [ of OR incorporated in England and Wales (company registration number [ number ]) with its registered office at ] [ address ] (Guarantor) ] [ [ name of Mortgagee ] [ of OR incorporated in England and Wales (company registration number [ number ]) with its registered office at ] [ address ] (Mortgagee) ] Definitions Within this Deed, the terms below shall be interpreted as follows: [ Annual Rent • the annual sum reserved under the Lease; ] [ Insurance Rent • the Tenant’s share of the Landlord’s costs of insuring the Property (as set out in the Lease); ] Lease • the lease of the Property dated [ date ], entered into between (1) [ the Landlord OR [ name ...
I, [ name ], of [ address ], solemnly and sincerely state that: [ Matters to be verified, set out in numbered paragraphs ] I make this solemn statement in good conscience, believing it to be true, and pursuant to the provisions of the Statutory Declarations Act 1835. DECLARED at [ details ] this [ day ] day of [ month and year ] Before me ................................................................................ [ signature of the person before whom the declaration is made ] A [ commissioner for oaths OR [ solicitor OR [ insert other qualification ] ] authorised to administer oaths ]...