UK corporate offence of failure to prevent tax evasion
Welcome to the July edition of the UK Tax Round Up. This month features a call for evidence from the government on potential changes to the tax on carried interest and interesting decisions on the application of the carried...more
The Labour Party Manifesto for the election on 4 July 2024 has now been published. Our key tax takeaways from the manifesto for the asset management sector are as follows:.....more
Welcome to March’s edition of our UK Tax Round Up. This month has seen a number of interesting cases covering a range of issues, from the deductibility of costs against employment income to the place of effective management...more
Welcome to June’s edition of our UK Tax Round Up. Several interesting cases have been reported this month, including a range of issues relevant to UK withholding tax on interest being considered in Hargreaves. HMRC has also...more
As part of the Edinburgh Reforms announced by the UK Government (link back to “UK FS Reforms”), the UK Government has also confirmed that the “Investment Transactions List” (“ITL”) would be expanded to include cryptoassets....more
The First Tier Tax Tribunal on 29 June, 2022, issued its judgment in Bluecrest, the first case considering the application of the salaried member legislation to members of a hedge fund management LLP. The judgment will be of...more
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
The United Kingdom (U.K.) currently operates certain off-payroll working rules (commonly referred to as IR35), which subject certain individuals (often operating as consultants to businesses) working through intermediaries...more
With a number of changes affecting the private wealth world to come over the next 12 months, our private client team take a look at some of the key UK legal developments for 2020, including the extension of the UK trust...more
Key Points - The off-payroll rules (IR35) aim to stop individuals from avoiding employee status for tax purposes (and thereby reducing the income tax and National Insurance Contributions (NICs) payable) by supplying their...more
New rules to be introduced from April 2020 will make certain companies who engage workers through intermediaries (the “client”) subject to...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
With effect from 6 April 2020, medium and large organisations in the private sector will become responsible for determining the employment status of individuals who provide services to such organisations through...more
Welcome to the March edition of the Proskauer UK Tax Round Up. As promised, the Spring Statement from the Chancellor focused on the economy and public finances without any major tax announcements. However, a few interesting...more
Welcome to our monthly update on current legal issues for trustees of DB and hybrid pension schemes, designed to help you stay up-to-date with key developments between trustee meetings, and to support the legal update item on...more
After numerous UK tax changes affecting asset managers over the past few years – not least the wholesale re-vamping of the tax treatment of carried interest and other fund participations for investment fund managers – the UK...more
The shifting sands of the taxation landscape for investment managers continues apace. Just when you perceive an oasis of stability on the horizon, it is revealed to be a mirage by the announcement of yet further changes....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
In the recent Summer Budget, the Chancellor announced that with immediate effect, there would be changes to the way that carried interest is taxed. In technical terms, the “base cost shift” which enabled an investment manager...more
On July 8, the Right Honourable George Osborne MP, Chancellor of the Exchequer, introduced measures in his Summer Budget to abolish what is commonly known as the “base cost shift” as applied to sums received by individuals...more
On 8th July 2015, the UK Government announced several changes to UK tax legislation that will affect those holding carried interest in fund structures which utilise at least one partnership (including a limited partnership),...more
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
New rules effective from today in the U.K. are likely to have material impact on the tax treatment of payments by a fund to its U.K.-based management executives and service providers. The rules cover many areas of fund...more
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