On 29 July, the UK government issued a call for evidence in connection with its proposed reform of the UK taxation of carried interest. Noting that the tax treatment of carried interest is the subject of considerable debate,...more
Sovereign immunity is a principle of public international law whereby one sovereign state should not seek to apply its law to another sovereign state. Alongside the jurisdictional immunity foreign sovereigns enjoy in the...more
HM Revenue and Customs (HMRC) published draft legislation on 14 September for inclusion in Finance Bill 2023-24, which will remove the 1.5% charge to UK stamp duty and stamp duty reserve tax (SDRT) with respect to the issue...more
The Abu Dhabi Global Market (ADGM) is fast becoming an international financial hub in the MENA region for global hedge fund managers that are drawn to the quality of the ADGM’s independent regulator, the Financial Services...more
The UK government’s “Growth Plan” (or “mini-budget”), delivered on 23 September, announced that the recent changes to the United Kingdom’s off-payroll working rules will be repealed with effect from April 2023....more
Despite the market disruption caused by the COVID-19 pandemic, sovereign wealth funds continued to make significant capital commitments to private funds during 2020, on a global basis. As the world emerges from the pandemic,...more
3/9/2021
/ Corporate Taxes ,
Financial Services Industry ,
Income Taxes ,
Internal Revenue Code (IRC) ,
International Tax Issues ,
Investment Management ,
IRS ,
Private Investment Funds ,
Sovereign Wealth Funds ,
Tax Assessment ,
Tax Evasion ,
Tax Liability
Coinciding with the end of the UK-EU Brexit transition period, the United Kingdom has dramatically reduced the scope of DAC 6 reporting obligations in the United Kingdom. ...more
Businesses in the United Kingdom which engage contractors through intermediaries should prepare now for changes to the “IR35” rules that will take effect in April 2021. ...more
A new act in the United Kingdom provides power to HMRC to claw back coronavirus (COVID-19) support payments and issue penalties for deliberate and inadvertent misuse of such schemes....more
HM Revenue & Customs confirmed on June 25, 2020, that the United Kingdom will adopt a European Union measure to delay the first reporting requirement under EU Council Directive 2018/822, the sixth amendment to the EU...more
HM Revenue & Customs has made available further details to the UK government’s 20 March announcement on a series of initiatives, including a valued added tax deferral, to support British businesses in the face of the...more
HM Revenue & Customs has released guidance setting out temporary changes to its stamping procedure, which will apply for the duration of the coronavirus (COVID-19) measures in the United Kingdom. ...more
The UK government has made a number of announcements that may affect individuals who are UK resident taxpayers, including income tax deferral and statutory sick pay changes, during the coronavirus (COVID-19) pandemic....more
The UK government recently announced a series of further initiatives to support British businesses in the face of the coronavirus (COVID-19) pandemic, including a VAT deferral and business rate holidays....more
The European Union has updated its list of non-cooperative tax jurisdictions to include the Cayman Islands. This addition could have certain repercussions for fund managers, sponsors, and investors operating through the...more
Individuals not resident in Kazakhstan are subject to taxation on certain Kazakhstan-source income. This Insight provides information on what income is taxable, what exemptions apply, and the general taxation procedure, and...more
The UK government has recently published draft legislation that, from April 2020, will require many private sector businesses engaging self-employed contractors through intermediary service companies to consider whether...more
HM Revenue & Customs has provided a timely reminder of the need for organisations with a connection to the United Kingdom to review their prevention procedures regarding the failure to prevent the facilitation of tax evasion...more
The European Commission (the Commission) published on 2 April a summary of its findings on a state aid investigation into the United Kingdom’s controlled foreign company (CFC) finance company exemption. The Commission has...more
The EU’s Economic and Financial Affairs (Ecofin) Council updated the European Union’s list of non-cooperative jurisdictions for tax purposes on March 12. The “blacklist” has tripled in length to comprise 15 countries and now...more
An important update to the Controlled Foreign Corporations (CFC) regime, which is expected to be adopted in March, is being considered in Kazakhstan to narrow the scope of the CFC rules temporarily....more
HM Revenue & Customs has released guidance interpreting the UK tax code for individuals dealing in cryptoassets. While most transactions are assumed to be part of investment activities, certain transactions in cryptoassets...more
The UK government seeks representations from stakeholders regarding the design of its proposed “digital services tax,” which would apply to search engines, social media platforms, and online marketplaces, and levy a 2% tax on...more
The code includes some key changes in the taxation of dividends, interest, and capital gains....more
Does the United Kingdom’s vote to leave the European Union change the United Kingdom’s attractiveness as a holding company jurisdiction?...more