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
Focus remains on the transition away from the London Interbank Offered Rate (LIBOR), a key interest rate benchmark that is referenced across many of the agreements that you, funds you manage or advise or entities that you...more
This note sets out at a high level the core regulatory issues that are likely to impact fund managers in the coming months, including an overview of the key actions needed with regard to ESG, LIBOR and Brexit. The paper also...more
5/10/2021
/ Alternative Investment Fund Managers Directive (AIFMD) ,
Cryptoassets ,
Environmental Social & Governance (ESG) ,
EU ,
Financial Conduct Authority (FCA) ,
Financial Services Industry ,
FinTech ,
Fund Managers ,
Investment Management ,
Libor ,
Private Funds ,
Securities and Exchange Commission (SEC) ,
UK ,
UK Brexit
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
A compact summary of the most recent regulatory and tax developments relevant to the UK asset management industry. This issue includes details of the FCA’s stance on the reporting of cyber attacks; the Government’s opinion on...more
12/13/2017
/ Asset Management ,
Cyber Attacks ,
Cybersecurity ,
Data Breach ,
EMIR ,
EU ,
European Central Bank ,
European Supervisory Authorities (ESAs) ,
Financial Conduct Authority (FCA) ,
Hackers ,
Investment Management ,
Jurisdiction ,
Regulatory Oversight ,
UK ,
Variation Margin Requirements (VM)
HM Treasury recently published its Investment Management Strategy II Report. Building on its 2013 strategy report ? which mainly focused on how to improve the UK as a fund domicile ? this report sets out the UK government’s...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
10/10/2015
/ Anti-Avoidance ,
Budgets ,
Capital Gains ,
Carried Interest ,
Carried Interest Tax Rates ,
Corporate Taxes ,
Cost-Shifting ,
Double Taxation ,
HMRC ,
Investment Management ,
Private Equity ,
Resident Non-Domiciled (RND) ,
Tax Credits ,
UK
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
7/16/2015
/ Anti-Avoidance ,
Budgets ,
Capital Gains ,
Carried Interest ,
Corporate Taxes ,
HMRC ,
Investment Management ,
Private Equity ,
Resident Non-Domiciled (RND) ,
Tax Reform ,
UK
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