David Gubbay

David Gubbay

Dechert LLP

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Pre-Budget Review: Changes to the Taxation of Mixed Partnerships in the UK

Background - HMRC published a consultation document on 20 May 2013 which proposed major changes to the taxation of partnerships. This was of particular relevance to investment management LLPs – and especially to those...more

12/6/2013 - Business Taxes LLPs Partnerships UK

Financial Conduct Authority Guidance on AIFM Directive Remuneration Provisions

The UK Financial Conduct Authority (FCA) released proposed guidance on 6 September 2013 on its implementation of the remuneration provisions in the AIFM Directive (the AIFM Remuneration Code) for UK alternative investment...more

10/17/2013 - AIFM AIFMD ESMA EU FCA Remuneration UCITS UK

OECD Sets Out Ambitious Global Plan to Tackle Tax Fairness Issues

The Organisation for Economic Co-operation and Development (OECD) issued an “Action Plan” to tackle “Base Erosion and Profit Shifting” (“BEPS”) on 19 July 2013. The concept of BEPS covers a range of international tax...more

7/24/2013 - Enforcement Actions Fairness Hearings G20 OECD Tax Rates Tax Reform

HM Treasury Rethinks the UK Tax Treatment of Fee Rebates

In a Written Ministerial Statement made in UK Parliament on 21 May 2013, Treasury Economic Secretary Sajid Javid MP announced the Treasury’s intention to make a crucial and very welcome clarification to the recent HMRC Brief...more

5/22/2013

HM Revenue & Customs Consultation Document Poses Significant Tax Challenges for Investment Management LLPs

On 20th May, HMRC published a consultation document which proposes major changes to the taxation of partnerships in the UK. The consultation is particularly relevant to investment management LLPs – and especially to those...more

5/21/2013 - Corporate Taxes Income Taxes Investment Management LLPs Partnerships

Recent ECJ VAT Decisions on Investment Management

Two recent decisions of the European Court of Justice (“ECJ”) on the VAT treatment of investment management services illustrate that this is still an area of some uncertainty that is continuing to evolve. The first decision,...more

3/19/2013 - EU Investment Adviser Investment Management Risk Management VAT Exemptions

Financial Services Tax - UK Update from Dechert's Tax Group - February 2013: Adoption of the European FTT

On 22 January 2013, the Council of the European Union adopted a decision authorising eleven countries - Belgium, Germany, Estonia, Greece, Spain, France, Italy, Austria, Portugal, Slovenia and Slovakia — to proceed with the...more

2/15/2013 - EU Financial Transaction Tax

Financial Services Tax – UK Update from Dechert’s Tax Group - February 2013: Privilege and Prudence

Legal advice privilege has seized the focus of attention yet again, as a result of the UK Supreme Court’s decision in Prudential delivered on 23 January 2013. In overview, Prudential sought to withhold documents including...more

2/14/2013 - Accountants EU HMRC Legal Advice Privilege Prudential

Financial Services Tax – UK Update from Dechert’s Tax Group - February 2013: Get Ready for the GAAR

Draft clauses to introduce a new general anti-abuse rule (GAAR) into the UK tax code were published as part of the Finance Bill 2013 on 11 December 2012. Some form of general anti avoidance rule was first seriously canvassed...more

2/12/2013 - Anti-Abuse Rule EU GAAR Tax Avoidance The Finance Bill 2013

Financial Services Tax – UK Update from Dechert’s Tax Group: Rule Changes Yield Mixed Blessings for UK Investors in Offshore Funds

UK investors in closely held offshore funds can be directly liable for tax if the fund makes a gain on an underlying asset even if the gain is reinvested by the fund and not distributed to the investor. There is also the...more

2/11/2013 - Capital Gains Double Taxation Investors Liquidation Offshore Funds Privately Held Corporations Section 13 Taxation of Chargeable Gains Act 1992

Financial Services Tax – UK Update from Dechert’s Tax Group - February 2013: FATCA Update – No Duplicate Reporting for Investment...

Following the execution of an inter-governmental agreement (or “IGA”) with the United States in September 2012 and a consultation exercise which closed in late 2012, HM Revenue & Customs (“HMRC”) recently published draft...more

2/8/2013 - EU FATCA HMRC Intergovernmental Agreements Investment Funds Investment Management IRS Partnerships

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