Bluecrest - Court of Appeal Narrows “Significant Influence” Test for LLP...
The Court of Appeal has taken an unexpectedly narrow and unfavourable interpretation of the significant influence test (Condition B) of the LLP salaried member rules in HMRC v Bluecrest Capital...
View ArticleLabour Budget 2024: Reforms to the Taxation of Carried Interest
The Chancellor of the Exchequer, Rachel Reeves MP, presented her first Budget to Parliament on 30 October 2024. In it, she announced both tax rate increases and also proposals which would fundamentally...
View ArticleInternational Comparative Legal Guide – Private Equity 2024
For the sixth consecutive year, Dechert is the contributing editor of the International Comparative Legal Guide - Private Equity. The guide, now in its tenth edition, is one of the most comprehensive...
View ArticleLabour Party Manifesto: Key Tax Points for Investment Managers
The Labour Party Manifesto for the election on 4 July 2024 has now been published. Our key tax takeaways from the manifesto for the asset management sector are as follows:.....By:
View ArticleUpper Tribunal Affirms FTT Bluecrest Decision on LLP Salaried Member Rules
Asset managers established as LLPs will welcome the Upper Tribunal’s recent decision to uphold the decision of the First Tier Tax Tribunal (“FTT”) on the application of the salaried member rules in...
View ArticleNew Luxembourg-UK Double Tax Treaty Will Introduce Key Changes Including...
Following the Luxembourg parliament’s ratification of the new Luxembourg-UK double tax treaty (“DTT”) on 19 July 2023, the new DTT should take effect in 2024. The UK ratified the new DTT on 7 June...
View ArticleUK amends and clarifies the UK qualifying asset holding company (QAHC) regime
The UK government on 23 March 2023 published proposed amendments to the recently enacted UK qualifying asset holding company (“QAHC”) regime. Seeking to help the QAHC regime better operate as intended,...
View ArticleReform to the UK Investment Manager Exemption – Certain Cryptoassets Added to...
In the summer of 2022, the UK government consulted on extending the scope of the UK Investment Manager Exemption (the “UK IME”) to include direct transactions in cryptoassets. Our previous OnPoint on...
View ArticleLearnings from Bluecrest – Investment Management LLPs and the Salaried Member...
The First Tier Tax Tribunal on 29 June, 2022, issued its judgment in Bluecrest, the first case considering the application of the salaried member legislation to members of a hedge fund management LLP....
View ArticleProposed reforms to sovereign immunity from UK direct tax – Government...
On 4 July 2022, the government published a consultation document calling for engagement in relation to proposed reforms to clarify who is entitled to benefit from sovereign immunity and also to...
View ArticleHMRC’s new QAHC guidance clarifies key activity test - providing greater...
Updated guidance in relation to the new Qualifying Asset Holding Company (QAHC), which was launched in April this year, has just been published at IFM40260. Amongst other things, the guidance provides...
View ArticleThe UK Investment Manager Exemption and Cryptoassets – Consultation Document
As part of wider efforts to make Britain a global hub for cryptoassets technology and investment, on 4 April 2022 the government publicly committed to consult on extending the scope of the UK...
View ArticleATAD 3 (Shell Companies) – Potential Implications for Fund Structures
A draft EU Council directive, known as ATAD 3, was issued by the European Commission as a proposal at the end of last year. The directive is aimed at countering the misuse of 'shell' entities and could...
View ArticleNotification of Uncertain Tax Treatment by Large Businesses in the UK
On 20 July 2021 (or so-called “Legislation Day 2021”), amongst a raft of other items, the UK government published its response to its second consultation on proposals for a new legislative regime that...
View ArticleUK Qualifying Asset Holding Companies: How Will the Proposals Impact Debt Funds?
The structure is a simplified version of how a typical European fund might be established in Luxembourg where currently we would typically use a downstream Luxembourg SARL or securitisation vehicle as...
View ArticleUK Life Sciences and Healthcare Newsletter - March 2021: Granting Incentives...
One of the most effective ways to incentivise staff, in particular senior employees, is to offer them the opportunity to purchase stock or shares in a group company. U.S. companies often operate stock...
View ArticleUK Life Sciences and Healthcare Newsletter - March 2021: Future Fund:...
Following the successful run of the government-backed Future Fund, the British Business Bank has announced that it is set to launch a further fund for development, Future Fund: Breakthrough. This...
View ArticleReminder: less than three months until revised IR35 rules come into force
In the light of the various business challenges posed by the ongoing COVID-19 pandemic, it would be understandable if the incoming changes to the off payroll working rules ('IR35') have not been a...
View ArticleUK Asset Holding Companies – Alternative Credit Funds: A Chance to Shape the...
The UK government has published a response to the consultation announced last year in relation to the possible introduction of a new tax advantaged regime for UK asset holding companies (AHC) used in...
View ArticleSome Good News at Last: The Government Substantially Restricts DAC6 Reporting...
Following the agreement of the EU/UK Trade and Cooperation Agreement (the “Brexit Deal”), HMRC has unexpectedly announced a substantial restriction to the way in which DAC6 will be applied in the UK....
View Article
![[-100%] Commodity Intelligence – (Android Apps)](http://play-lh.googleusercontent.com/j67-qJvmnn4xnVlYVZ9ZhtZUJIgwjKekJGoKQT6D1KHcWGZxtQaFroummEvwV17na7tyh1pGbbeWCRdWtTKqeg=w950-h950)
