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
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
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