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 will require large...more
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 the intermediate...more
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 the context of...more
Non-UK resident companies play a variety of roles in fund structures managed by UK based asset managers. They are commonly used as the fund vehicle itself, as the general partner of a limited partnership fund vehicle, and/or...more
The UK House of Commons has rejected the government’s proposed Withdrawal Agreement. Unless the Agreement (or an amended version of it) is approved by the House of Commons, or the Brexit date of 29 March 2019 is postponed or...more
1/16/2019
/ AIFM ,
Alternative Investment Fund Managers Directive (AIFMD) ,
Asset Management ,
Contract Terms ,
Corporate Counsel ,
Corporate Taxes ,
Cross-Border Transactions ,
EU ,
Exports ,
Free Movement ,
Imports ,
Intellectual Property Protection ,
MiFID II ,
No-Deal Brexit ,
Supply Chain ,
Tax Treaty ,
Trade Policy ,
Trade Relations ,
Transitional Arrangements ,
UCITS ,
UK ,
UK Brexit ,
Withdrawal Agreement
A compact summary of the most recent regulatory developments relevant to the UK asset management industry. This issue includes details of the FCA’s statement on the implementation period for Brexit; the requirement for firms...more
4/20/2018
/ Asset Management ,
BEPS ,
Corporate Taxes ,
Cross-Border ,
Cryptocurrency ,
Customer-Loyalty Programs ,
Cybersecurity ,
Derivatives ,
EU ,
Financial Conduct Authority (FCA) ,
Financial Services Industry ,
MiFID II ,
MiFIR ,
UK ,
UK Brexit
HM Treasury recently published its Investment Management Strategy II Report. Building on its 2013 strategy report ? which mainly focused on how to improve the UK as a fund domicile ? this report sets out the UK government’s...more
A compact summary of the most recent regulatory and tax developments relevant to the UK asset management industry. This issue includes details on ESMA’s updated Q&As on the key information document requirements for PRIIPs;...more
11/29/2017
/ Autumn Statement ,
Commercial Real Estate Market ,
Corporate Taxes ,
Derivatives ,
EMIR ,
EU ,
EU Market Abuse Regulation (EU MAR) ,
European Securities and Markets Authority (ESMA) ,
Hedge Funds ,
HMRC ,
IOSCO ,
Key Information Document (KIDs) ,
Legal Entity Identifiers ,
MiFID II ,
Money Market Funds ,
Non-Resident Income Taxes ,
Over The Counter Derivatives (OTC) ,
Packaged Retail And Insurance-Based Investment Products (PRIIPS) ,
Real Estate Investments ,
Tax Reform ,
UK
In his first (and last) Autumn Statement, the Chancellor of the Exchequer, Philip Hammond, announced a number of tax measures affecting the financial services industry, although many of these changes had been the subject of...more
Historically, UK resident non-domiciled individuals have been able to achieve certain tax advantages through holding interests in UK residential property through offshore companies. In recent years, the UK government has...more
The political, economic and constitutional fallout of the UK’s referendum decision to leave the European Union (Brexit) will continue for some time. In addition to considering some of the possible domestic UK tax implications...more
7/2/2016
/ CFCs ,
Controlled Foreign Corporations ,
Corporate Taxes ,
Customs ,
Dividends ,
EU ,
European Economic Area (EEA) ,
Exit Tax ,
ICAV ,
Income Taxes ,
International Tax Issues ,
Referendums ,
Stamp Taxes ,
Tax Treaty ,
Transfer Pricing ,
UK ,
UK Brexit ,
Value-Added Tax (VAT)
Interest paid by UK companies is generally subject to withholding tax at 20%. Although various exemptions apply, most notably in respect of interest payments to banks and other UK companies, and in respect of securities...more
The Chancellor of the Exchequer’s recent Summer Budget and the related legislation introduced a series of unexpected tax changes along with the promise of further changes to come. Shortly after the Summer Budget was issued...more
10/10/2015
/ Anti-Avoidance ,
Budgets ,
Capital Gains ,
Carried Interest ,
Carried Interest Tax Rates ,
Corporate Taxes ,
Cost-Shifting ,
Double Taxation ,
HMRC ,
Investment Management ,
Private Equity ,
Resident Non-Domiciled (RND) ,
Tax Credits ,
UK
The Chancellor of the Exchequer’s Summer Budget on 8th July introduced a series of unexpected tax changes affecting the private equity and investment management industry along with the promise of further changes to come....more
7/16/2015
/ Anti-Avoidance ,
Budgets ,
Capital Gains ,
Carried Interest ,
Corporate Taxes ,
HMRC ,
Investment Management ,
Private Equity ,
Resident Non-Domiciled (RND) ,
Tax Reform ,
UK
Following the taxpayer’s victory in the recent Supreme Court decision of HMRC v Anson, UK resident members of Delaware LLCs may now be entitled to claim relief against their UK tax liabilities for US tax paid on their share...more
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