The “retailisation” of private funds has been one of the industry’s most significant trends in recent years, with fund managers seeking sources of capital beyond their usual institutional, professional and sophisticated...more
9/5/2024
/ Asset Management ,
Capital Raising ,
ELTIF ,
EU ,
EuVECA ,
Financial Conduct Authority (FCA) ,
Fund Managers ,
Investors ,
Private Funds ,
UCITS ,
UK
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 newly elected UK Labour government published its call for evidence (see link here) on the taxation of carried interest on Monday 29 July 2024. This consultation by HM Treasury, cautiously anticipated following statements...more
Welcome to the June edition of the UK Tax Round Up. This month features the latest Court of Appeal decision in a trilogy of recent cases regarding the loan relationship “unallowable purpose” test, an Upper Tribunal decision...more
Welcome to April’s edition of our UK Tax Round Up. This month has seen a number of interesting decisions covering the application of the transfer pricing rules and the unallowable purpose test to an intragroup financing...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
4/10/2024
/ Acquisitions ,
Asset Management ,
Corporate Governance ,
HMRC ,
Income Taxes ,
Investment Management ,
Legislative Agendas ,
Mergers ,
Private Equity ,
Private Equity Funds ,
Shareholders ,
Taxation ,
UK
Settlement payment subject to tax as employment income -
In Mathur v HMRC, the Upper Tribunal (UT) has upheld the FTT’s decision that a £6 million settlement payment to a former employee following an employment tribunal...more
3/11/2024
/ Capital Contributions ,
EU ,
HMRC ,
Income Taxes ,
Interest Rates ,
Investigations ,
Jurisdiction ,
Price Manipulation ,
Professional Regulators ,
Settlement ,
Termination ,
UK
As part of the UK’s Spring Budget 2024, the Chancellor of the Exchequer, Jeremy Hunt, has announced the abolition of the remittance basis for income tax and capital gains tax for non-UK domiciled, UK resident individuals (the...more
Welcome to January’s edition of our UK Tax Round Up. It was announced this month that the next UK Budget will take place on 6 March 2024. HMRC also published responses on its permanent establishment consultation. In addition,...more
Welcome to December’s edition of our UK Tax Round Up. This month has seen two interesting decisions on the connections needed for amounts to be taxed as employment income, the latest instalment in the BlueCrest partner...more
1/5/2024
/ Appeals ,
Artificial Intelligence ,
Capital Gains ,
Classification ,
Double Taxation ,
Employment Tax ,
HMRC ,
Limited Liability Company (LLC) ,
Luxembourg ,
Machine Learning ,
Pensions ,
UK
Welcome to November’s edition of the UK Tax Round Up. This month has seen the Chancellor’s Autumn Statement as well as an interesting confirmation from the Court of Appeal on the scope of “arrangements” for capital gains tax...more
12/12/2023
/ Capital Gains Tax ,
HMRC ,
Investment ,
National Insurance Contributions ,
OECD ,
Pensions ,
Private Equity ,
Tax Avoidance ,
Tax Credits ,
Transfer of Assets ,
UK ,
Venture Capital
Welcome to the October edition of the UK Tax Round Up. This month has seen the Supreme Court’s judgment on the operation of the employment-related securities deeming provision, the Court of Appeal’s decision on what...more
11/6/2023
/ Appeals ,
Business Succession ,
Cayman Islands ,
Court of Justice of the European Union (CJEU) ,
Debt ,
Draft Guidance ,
EU ,
Hedge Funds ,
HMRC ,
Loan Repayment Issues ,
Partnership Agreements ,
Pensions ,
Securities ,
UK ,
Value-Added Tax (VAT)
Welcome to the September edition of the UK Tax Round Up. This month has seen interesting decisions on the salaried members rules, the scope of arrangements for the CGT rollover main tax avoidance purpose test and the...more
10/12/2023
/ Compensation ,
Film Industry ,
GAAP ,
HMRC ,
Investment ,
Private Limited Companies ,
Subsidies ,
Tax Avoidance ,
Tax Deductions ,
Tax Exemptions ,
Tax Planning ,
UK
Welcome to July’s edition of our UK Tax Round Up. This month has seen a number of interesting tribunal decisions, including the denial of double tax relief and of employee expense deductions and the taxation on loans to a...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
7/5/2023
/ Bank of England ,
Cryptoassets ,
HMRC ,
Investment Management ,
Loan Agreements ,
National Asset Management Agency (NAMA) ,
OECD ,
Pensions ,
SAYE/Sharesave Plan ,
SIP ,
UK ,
Withholding Tax
Welcome to May’s edition of our UK Tax Round. This month has been relatively quiet but there were a couple of cases that affect transactions that we see in practice, including an interesting update on what could constitute a...more
Welcome to April’s edition of our UK Tax Round Up. This month has seen a number of interesting cases highlighting the need for taxpayers and HMRC alike to apply a realistic approach to the facts in assessing the tax...more
Welcome to February’s edition of our UK Tax Round Up. The month has seen interesting cases on the “entitlement” to income and the single and multiple supply tests for VAT as well as announcement of the publication date for...more
VAT incurred on corporate advisory fees not recoverable -
In Ince Gordon Dadds LLP v HMRC, the First-tier Tribunal (FTT) has decided that Ince Gordon Dadds LLP (formerly Culver Holdings Limited and the taxpayer) (Culver)...more
2/1/2023
/ Acquisitions ,
Annotated Case Law ,
Appeals ,
Court of Justice of the European Union (CJEU) ,
GAAP ,
HMRC ,
International Tax Issues ,
OECD ,
Personal Services ,
Research and Development ,
UK ,
Value-Added Tax (VAT)
Welcome to the November edition of the UK Tax Round Up. This month has seen the new Chancellor deliver his Autumn Statement following from the previous Chancellor’s so-called mini budget in October and the Court of Appeal’s...more
12/6/2022
/ Appeals ,
Bank Taxes ,
Capital Gains ,
Diverted Profits Tax ,
Dividends ,
HMRC ,
Income Taxes ,
Inheritance Tax ,
OECD ,
Transfer Taxes ,
UK
Welcome to the October edition of the UK Tax Round Up. October has been an extraordinary month in the UK, with political turbulence triggering reversals of many of the tax policies announced by the government at the end of...more
11/1/2022
/ Double Taxation ,
EU ,
European Court of Justice (ECJ) ,
HMRC ,
Income Taxes ,
Interest Rate Adjustments ,
Reversal ,
Tax Liability ,
Tax Policy ,
UK ,
Value-Added Tax (VAT)
Welcome to September’s edition of the UK Tax Round Up. In addition to the headline-grabbing 2022 Growth Plan announced by the UK Chancellor, there have been a number of interesting cases this month including the First-tier...more
9/30/2022
/ Advocate General ,
Business Taxes ,
Debtors ,
Dispute Resolution ,
Double Taxation ,
Enforcement ,
EU ,
European Court of Justice (ECJ) ,
Fair Market Value ,
HMRC ,
Income Taxes ,
Indemnity ,
Purchase Agreement ,
Shareholders ,
Tax Loopholes ,
UK
Welcome to the August edition of the UK Tax Round Up. August turned out to be not such a quiet month on the UK tax front. We have seen several important and technical case law decisions, some of which we discuss below, and...more
Welcome to July’s edition of the UK Tax Round Up. This month has seen an interesting decision of the First-tier Tribunal on the salaried member rules as they apply to asset manager LLPs, a surprising decision on the terms...more
The recent decision of the First-tier Tribunal (FTT) in BlueCrest Capital Management (UK) LLP v HMRC (29 June 2022) is the first time the UK’s salaried member rules (the Rules) have been considered in the context of an asset...more