While most of the European Anti-Hybrid Rules took effect on 1 January 2020, the last anti-hybrid provision – targeting the reverse hybrid mismatch – will enter into force in relevant EU jurisdictions (such as Luxembourg and...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
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
Since the financial crisis of 2008 / 2009, swathes of new regulations have been introduced governing various aspects of remuneration in the financial services sector. A key feature of these rules is the compulsory clawback of...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)
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