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
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
7/14/2022
/ Distribution Rules ,
Employment Tax ,
Financial Services Industry ,
Hedge Funds ,
HMRC ,
International Tax Issues ,
Investment Management ,
Limited Liability Partnerships ,
Remuneration ,
Salaried Employees ,
Tax Liability ,
UK
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
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
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
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
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
Two recent decisions of the European Court of Justice (“ECJ”) on the VAT treatment of investment management services illustrate that this is still an area of some uncertainty that is continuing to evolve. The first decision,...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