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Labour Party Manifesto: Key Tax Points for Investment Managers

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

Upper Tribunal Affirms FTT Bluecrest Decision on LLP Salaried Member Rules

Asset managers established as LLPs will welcome the Upper Tribunal’s recent decision to uphold the decision of the First Tier Tax Tribunal (“FTT”) on the application of the salaried member rules in Bluecrest...more

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

UK amends and clarifies the UK qualifying asset holding company (QAHC) regime

The UK government on 23 March 2023 published proposed amendments to the recently enacted UK qualifying asset holding company (“QAHC”) regime. Seeking to help the QAHC regime better operate as intended, the amendments address...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

Learnings from Bluecrest – Investment Management LLPs and the Salaried Member Rules

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

Proposed reforms to sovereign immunity from UK direct tax – Government Consultation

On 4 July 2022, the government published a consultation document calling for engagement in relation to proposed reforms to clarify who is entitled to benefit from sovereign immunity and also to restrict the availability of...more

HMRC’s new QAHC guidance clarifies key activity test - providing greater certainty for funds undertaking credit and loan...

Updated guidance in relation to the new Qualifying Asset Holding Company (QAHC), which was launched in April this year, has just been published at IFM40260. Amongst other things, the guidance provides a timely boost to the...more

The UK Investment Manager Exemption and Cryptoassets – Consultation Document

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

Notification of Uncertain Tax Treatment by Large Businesses in the UK

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

8/6/2021  /  Corporate Taxes , HMRC , Penalties , Tax Planning , UK

Reminder: less than three months until revised IR35 rules come into force

In the light of the various business challenges posed by the ongoing COVID-19 pandemic, it would be understandable if the incoming changes to the off payroll working rules ('IR35') have not been a primary focus for some...more

Some Good News at Last: The Government Substantially Restricts DAC6 Reporting Obligations for UK Intermediaries

Following the agreement of the EU/UK Trade and Cooperation Agreement (the “Brexit Deal”), HMRC has unexpectedly announced a substantial restriction to the way in which DAC6 will be applied in the UK. Although the law has...more

EU Commission proposes extension of the DAC6 reporting deadlines

On Friday 8 May 2020, the European Commission announced a proposal to postpone by three months the initial reporting deadlines for “DAC6”, the incoming mandatory disclosure regime for potentially aggressive tax arrangements....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

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

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

2020/03/12 UK Budget 2020 – Asset Holding Companies in Alternative Fund Structures

As part of the series of announcements made in the 2020 Budget, HM Treasury released a consultation document relating to the tax treatment of UK asset holding companies in the context of alternative fund structures... The...more

Financial Services Quarterly Report - Third Quarter 2019: Developments in the UK Tax Treatment of Fee Rebates and Trail...

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

HMRC’s Implementation of EU Mandatory Tax Disclosure Rules

HMRC has released a consultation document in respect of its draft regulations implementing the EU mandatory tax disclosure rules that will apply from 1 July 2020 to intermediaries and relevant taxpayers in relation to...more

Off-payroll working rules and the investment management industry from April 2020

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

Asset Management Regulatory Roundup - April 2018 - Issue 7

A compact summary of the most recent regulatory developments relevant to the UK asset management industry. This issue includes details of the FCA’s statement on the implementation period for Brexit; the requirement for firms...more

Asset Management Regulatory Roundup - December 2017 - Issue 12

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

HMT Unveils Strategy for Future of UK's Asset Management Industry

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

Using corporate structures to own UK residential property – a dead end?

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

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