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JIBFL: Debt for equity swaps: a key restructuring tool in the post COVID-19 era

In this article Natalie Scoones, George Weavil and Jessica Kemp discuss why a debt for equity swap is likely to play a role in many restructurings that result from the downturn triggered by the COVID-19 pandemic. They explain how such transactions are structured, the likely motivations of key stakeholders and the tax and regulatory implications of such transactions.

Mini-Budget: Plan for Jobs

On 8th July the Chancellor delivered a "Plan for Jobs" aimed at stimulating the British economy, in particular the flagging hospitality sector and lacklustre housing market.

Taxation of Covid-19 support payments

This briefing was updated on 8 June 2020.

HMRC announced on 29 May 2020 that it will be consulting on draft legislation to tax certain of the Covid-19 support measures provided to businesses. 

Corporate tax residence, taxable presence and COVID-19

Companies with an international footprint will need to ensure that their tax residence (and other taxable presence) is not affected by travel restrictions imposed in response to the COVID-19 pandemic. HMRC has published guidance on these issues, which is somewhat helpful if less definitive than the approach of a number of other jurisdictions.

COVID-19: Liquidity, liquidity, liquidity

Over the last 4 weeks, in the face of COVID-19 the worldwide economy has experienced the sorts of pressures not seen since the Great Depression. Businesses around the world have been forced to close their doors; we have seen government interventions which, only 3 months ago, would have been unthinkable; and terms such as "social distancing" and "furloughing" have become common parlance.

Stamp duty: Temporary COVID-19 procedures

This briefing was updated on 13 May 2020.

HMRC have introduced temporary procedures for the payment of stamp duty on, and the stamping of, stock transfer forms and other instruments of transfer. Under the usual procedure, stock transfer forms are physically stamped using a specialised machine located at one of HMRC's offices.

Delay to the Off-Payroll reforms – What does it mean for your business?

On 17 March, the Government announced that the changes to the Off-Payroll rules (the 'New Rules'), due to come in on 6 April 2020, would be delayed by one year as part of a package of measures to ease pressure on businesses in light of the coronavirus outbreak. In these challenging times, the news was welcomed by clients and contractors concerned about the financial impact the changes would have on them.

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