UK COVID-19 Developments - Extension of support for retail, leisure and hospitality businesses - Further to the extension of the Coronavirus Job Retention Scheme (or furlough scheme), reported in the November issue of...more
On February 12, 2020, the Federal Court of Appeal (FCA) in Canada v Alta Energy Luxembourg S.A.R.L., 2020 FCA 43 [Alta Lux] concluded that the Canada-Luxembourg tax treaty (Can-Lux Treaty) was not abused when a Luxembourg...more
On May 29, 2019, Darcy Moch, Greg Johnson and Jared Mackey of Bennett Jones participated on a witness panel before the Standing Senate Committee on Foreign Affairs and International Trade to discuss the application of Bill...more
Tax-efficient holding structures commonly used by multinational enterprises and private equity firms investing in the Canadian resource sector could soon become subject to anti-treaty shopping measures contained in the...more
EU developments - European Court rules that withholding tax exemptions under EU Directives can be denied by abuse of rights principle - At the end of February, the Court of Justice of the European Union (CJEU) issued...more
Welcome to the March edition of the Proskauer UK Tax Round Up. As promised, the Spring Statement from the Chancellor focused on the economy and public finances without any major tax announcements. However, a few interesting...more
International Tax Developments - BEPS Multilateral Convention signed - On 7 June, officials from more than 60 jurisdictions signed the BEPS Multilateral Convention which will transplant a number of measures in respect...more
How do private equity funds typically obtain their funding? Private equity funds continued to have a diverse investor base in 2015. Although with a significant decrease from the 2014 figure of 68%, about 48% of the...more
Proposed new UK rules will tax carried interest in certain funds as income, with only specified funds entitled to capital gains treatment - The UK government published draft legislation on 9 December 2015 amending the...more
Further to our client alert in July this year, the UK Government recently proposed further changes to the UK taxation of carried interest and disguised investment management fees (DIMF). The UK Government proposed...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
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