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New Luxembourg-UK Double Tax Treaty Will Introduce Key Changes Including Access to Treaty Benefits for CIVs / Investment Funds

Following the Luxembourg parliament’s ratification of the new Luxembourg-UK double tax treaty (“DTT”) on 19 July 2023, the new DTT should take effect in 2024. The UK ratified the new DTT on 7 June 2022....more

Reform to the UK Investment Manager Exemption – Certain Cryptoassets Added to the Investment Transactions List

In the summer of 2022, the UK government consulted on extending the scope of the UK Investment Manager Exemption (the “UK IME”) to include direct transactions in cryptoassets. Our previous OnPoint on the consultation,...more

COVID-19: UK Tax Residence Risks for Offshore Funds and Related Entities – HMRC Update

Following on from our recent OnPoint (COVID-19: UK Tax Residence Risks for Offshore Funds and Related Entities), HMRC has now published guidance on the corporate residence issues posed by COVID-19. ...more

UK Commits to Introducing Targeted Digital Services Tax

The UK government yesterday announced that it will introduce a targeted Digital Services Tax aimed at large search engines, social media platforms and online marketplaces, applicable from April 2020. ...more

Financial Services Quarterly Report - Fourth Quarter 2016: UK Autumn Statement 2016: Tax-Related Impact for the Financial Services...

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

Financial Services Quarterly Report - Second Quarter 2016: OECD Common Reporting Standard: The Next Steps

The Common Reporting Standard (CRS) of the Organisation of Economic Co-operation and Development (OECD) came into effect on 1 January 2016 in “early adopter” jurisdictions, including the UK and popular fund jurisdictions such...more

The Common Reporting Standards - New Global Tax Information Exchange Regime Begins January 2016

The Common Reporting Standard (“CRS”) will impose new investor due diligence and reporting obligations on funds and other financial institutions based in “early adopter” participating jurisdictions, with effect from January...more

Financial Services Quarterly Report - Third Quarter 2015: Letter from Amsterdam: Dechert and European Private Equity CFOs and COOs...

Dechert was again pleased to support the SuperReturn CFO/COO Forum, held in Amsterdam in September. Nearly 200 GPs, LPs and key individuals from the private equity and venture capital industry came together for three days of...more

Financial Services Quarterly Report - Second Quarter 2015: OECD Discussion Draft on BEPS: Funds’ Treaty Access under Threat

The Organisation for Economic Co-operation and Development (OECD) published a revised discussion draft on 22 May 2015, in relation to Action 6 of the BEPS (Base Erosion and Profit Shifting) Action Plan (Action Plan 6), which...more

Worldwide Exchange of Tax Information: OECD Expands upon FATCA to Add New Requirements

While the Foreign Account Tax Compliance Act (FATCA) has focused worldwide attention on U.S. efforts to create a mandatory cross-border exchange of tax information, the enactment of FATCA was not an isolated occurrence. For...more

OECD Sets Out Ambitious Global Plan to Tackle Tax Fairness Issues

The Organisation for Economic Co-operation and Development (OECD) issued an “Action Plan” to tackle “Base Erosion and Profit Shifting” (“BEPS”) on 19 July 2013. The concept of BEPS covers a range of international tax...more

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