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 2022....more
This latest edition of the regulatory initiatives paper sets out at a high level the core regulatory issues that are likely to impact private fund managers in the coming months, including an overview of the key actions needed...more
9/22/2022
/ Alternative Reference Rates Committee (ARRC) ,
AML/CFT ,
Anti-Money Laundering ,
Beneficial Owner ,
CFTC ,
China ,
Climate Change ,
Commission Delegated Regulation ,
Coronavirus/COVID-19 ,
Cryptoassets ,
Custody Rule ,
Cybersecurity ,
Digital Currency ,
Disclosure Requirements ,
Diversity and Inclusion Standards (D&I) ,
Economic Sanctions ,
ELTIF ,
Environmental Social & Governance (ESG) ,
EONIA ,
EU ,
European Commission ,
European Securities and Markets Authority (ESMA) ,
European Supervisory Authorities (ESAs) ,
Financial Conduct Authority (FCA) ,
Financial Markets ,
Financial Services Act ,
Form PF ,
FSOC ,
Fund Managers ,
Hedge Funds ,
Hong Kong ,
ICE Benchmark Administration (IBA) ,
Investors ,
Libor ,
MiFID ,
MiFID II ,
Non-Fungible Tokens (NFTs) ,
Private Funds ,
Proposed Amendments ,
Regulatory Standards ,
REIT ,
Rulemaking Process ,
Russia ,
Secured Overnight Funding Rate (SOFR) ,
Securities and Exchange Commission (SEC) ,
Securities Exchange Act of 1934 ,
SFDR ,
Supply Chain ,
Temporary Permissions Regime (TPR) ,
UCITS ,
UK ,
UK Brexit ,
Ukraine
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 Investment Manager Exemption (the...more
5/27/2022
/ Cryptoassets ,
Cryptocurrency ,
Digital Assets ,
Financial Regulatory Reform ,
Financial Transactions ,
HMRC ,
Investment Fund Vehicles ,
Investment Management ,
Investment Opportunities ,
Investors ,
Regulatory Agenda ,
Smart Contracts ,
Tax Liability ,
UK
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
UK investment managers paying fee rebates, loyalty bonuses or similar payments to UK investors and certain non-UK investors in collective investment schemes should note recent case law developments regarding the tax treatment...more
10/25/2019
/ Advisory Commissions ,
Fees ,
Financial Services Industry ,
HMRC ,
Income Taxes ,
Investment Management ,
Investors ,
Loyalty Bonuses ,
Rebates ,
Reversal ,
Tax Appeals ,
Tax Tribunal ,
Taxable Income ,
UK
The Common Reporting Standard (CRS) of the Organisation of Economic Co-operation and Development (OECD) came into effect on 1 January 2016 in “early adopter” jurisdictions, including the UK and popular fund jurisdictions such...more
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