Amendments to Offshore Fund Rules to Reflect Finance Act 2014 AIFM Partnership Tax Changes

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Regulations amending the Offshore Funds Regulations 2009 (the 2009 Regulations) to reflect the Finance Act 2014 changes to the taxation of alternative investment fund managers operating as partnerships (AIFM firms) were made on July 21 and have effect for disposals made on or after August 12, 2014. The changes to the taxation of AIFM firms permit AIFM firms to elect for all or part of a partner’s “relevant restricted profit” to be allocated to the AIFM firm rather than from part of the partner’s profit share. Accordingly, the partner is not subject to tax on the profit. Instead, the AIFM is treated as a partner in the AIFM firm and is subject to income tax at the additional rate (currently 45 percent) on the allocated amount. The partner is subsequently subject to tax on the amount that vests, but will receive a tax credit for the tax paid by the AIFM firm. Regulations.


DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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