On Wednesday 30 October 2024, the UK government announced changes to the UK taxation of carried interest as part of the 2024 Autumn Budget. Changes were expected following statements made by the Labour Party in the run up to...more
11/12/2024
/ Capital Gains ,
Carried Interest ,
Carried Interest Tax Rates ,
Fund Managers ,
HMRC ,
Holding Periods ,
Income Taxes ,
Investment Funds ,
Tax Policy ,
Tax Rates ,
Tax Reform ,
UK
The newly elected UK Labour government published its call for evidence (see link here) on the taxation of carried interest on Monday 29 July 2024. This consultation by HM Treasury, cautiously anticipated following statements...more
As part of the UK’s Spring Budget 2024, the Chancellor of the Exchequer, Jeremy Hunt, has announced the abolition of the remittance basis for income tax and capital gains tax for non-UK domiciled, UK resident individuals (the...more
Welcome to May's edition of the UK Tax Round Up. This month has seen a number of interesting court decisions, an important opinion of the European Commission’s Advocate General and the commencement of a Treasury consultation...more
6/8/2022
/ Advocate General ,
Corporate Taxes ,
EU ,
Income Taxes ,
International Tax Issues ,
OECD ,
Remuneration ,
Tax Code ,
Tax Court ,
Tax Deductions ,
Tax Liability ,
Tax Reform ,
Transfer of Assets ,
UK ,
Value-Added Tax (VAT)
Welcome to the March edition of the Proskauer UK Tax Round Up. In his Spring Statement, the Chancellor focused on measures to alleviate the increasing cost of living and to boost investment in the economy but there were no...more
Welcome to February’s edition of our UK Tax Round Up. This month’s edition includes updated guidance on the VAT treatment of contractual termination payments, updated HMRC guidance on the assessment of “substantial”...more
UK Case Law Developments -
Contributions to remuneration trust scheme not tax deductible -
In Strategic Branding Ltd v HMRC, the First-tier Tribunal (FTT) held that sums contributed by the taxpayer company to a...more
2/10/2022
/ Business Losses ,
EU ,
GILTI tax ,
Income Taxes ,
International Tax Issues ,
Tax Code ,
Tax Court ,
Tax Deductions ,
Tax Reform ,
UK ,
Value-Added Tax (VAT)
UK Case Law Developments -
Taxpayer treated as receiving distribution in tax avoidance case -
We reported on First-tier Tribunal’s (FTT’s) decision in Dunsby v Revenue & Customs in our June 2020 UK Tax Round Up. By way...more
1/5/2022
/ Distribution Rules ,
Dividend-Equivalent Transactions ,
International Tax Issues ,
Legal Costs ,
Proposed Regulation ,
Regulatory Agenda ,
Share Class Structures ,
Stock Options ,
Tax Avoidance ,
Tax Code ,
Tax Court ,
Tax Liability ,
Tax Reform ,
UK ,
Value-Added Tax (VAT)
Welcome to November’s edition of the UK Tax Round Up. This month has seen publication of the Finance Bill 2021-22 (what will become the Finance Act 2022) including draft legislation for the basis period reform, UK asset...more
12/3/2021
/ Corporate Taxes ,
HMRC ,
Holding Companies ,
Income Taxes ,
International Tax Issues ,
IR35 ,
Tax Planning ,
Tax Rates ,
Tax Reform ,
UK ,
Withholding Tax
The Chancellor presented the Budget on 27 October. Although it contained a wide range of general spending and tax-related announcements, there was nothing of significance for the private funds industry that had not been...more
In Fashion on the Block Limited v HMRC, the First-tier Tribunal (FTT) has allowed the taxpayer’s appeal against HMRC’s decision not to allow the taxpayer company to issue seed enterprise investment scheme (SEIS) certificates...more
In Haworth v HMRC the Supreme Court (SC) upheld the Court of Appeal’s (CA’s) decision to quash a follower notice (FN) and accelerated payment notice (APN) issued to the taxpayer, Mr Haworth. An FN can be issued by HMRC where...more
8/2/2021
/ Accelerated Payments ,
Bonuses ,
Charitable Trusts ,
GAAR ,
HMRC ,
Income Taxes ,
International Tax Issues ,
Legislative Agendas ,
NICS ,
OECD ,
Preferred Shares ,
Proposed Legislation ,
Regulatory Agenda ,
Remuneration ,
Tax Avoidance ,
Tax Reform ,
UK ,
Valuation ,
Value-Added Tax (VAT)
The UK has now been in lockdown, on and off, for the best part of a year. With the COVID-19 vaccination programme now in full swing in the UK, and hopefully with light at the end of tunnel, attention has inevitably turned to...more
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
2/8/2021
/ Anti-Avoidance ,
Capital Gains ,
Capital Gains Tax ,
Coronavirus/COVID-19 ,
HMRC ,
Income Taxes ,
International Tax Issues ,
Job Retention Schemes ,
Partnerships ,
Tax Avoidance ,
Tax Exemptions ,
Tax Planning ,
Tax Reform ,
UK ,
Value-Added Tax (VAT)
UK COVID-19 Developments -
Extension of support for employed and self-employed workers -
On 5 November, the UK Chancellor announced the extension of the Coronavirus Job Retention Scheme (or furlough scheme) to the end...more
12/3/2020
/ Capital Gains Tax ,
Corporate Taxes ,
EU ,
HMRC ,
Income Taxes ,
International Tax Issues ,
Job Retention Schemes ,
Tax Avoidance ,
Tax Exemptions ,
Tax Planning ,
Tax Rates ,
Tax Reform ,
UK ,
Value-Added Tax (VAT)
UK General Tax Developments -
Date set for next UK Budget -
The first Budget of the new Conservative government will be held on Wednesday 11 March. There has been significant speculation that there will be a major...more
1/31/2020
/ Anti-Avoidance ,
Articles of Association ,
Corporate Taxes ,
Draft Guidance ,
Entrepreneurs ,
EU ,
HMRC ,
Income Taxes ,
International Tax Issues ,
Investment Funds ,
Partnerships ,
Private Equity ,
Remuneration ,
Tax Reform ,
UK ,
UK Brexit ,
Value-Added Tax (VAT)
UK Tax News and Developments -
The OTS publishes its report "Value added tax: routes to simplification" -
On 7 November, the Office of Tax Simplification (OTS) published its first report on VAT, which included a range...more
11/30/2017
/ CFC ,
Corporate Taxes ,
Court of Justice of the European Union (CJEU) ,
Diverted Profits Tax ,
Draft Guidance ,
EU ,
European Commission ,
HMRC ,
Income Taxes ,
International Tax Issues ,
National Insurance Contributions ,
OTS ,
Remuneration ,
Restitution ,
Self-Employment Tax ,
Tax Reform ,
Threshold Requirements ,
UK ,
Value-Added Tax (VAT)
UK Tax News and Developments - Finance (No 2) Bill 2017 - The second Finance Bill of 2017, known as Finance (No 2) Bill 2017, has now been published. As expected, this contains most of the provisions which were dropped from...more
9/22/2017
/ Corporate Taxes ,
Criminal Fascilitation ,
Debt Trading ,
Foreign Corporations ,
HMRC ,
OECD ,
OTS ,
Partnerships ,
Remuneration ,
SIFs ,
Stamp Taxes ,
Tax Avoidance ,
Tax Evasion ,
Tax Reform ,
Tax Tribunal ,
Transfer Pricing ,
UK ,
Value-Added Tax (VAT) ,
Withholding Tax
After numerous UK tax changes affecting asset managers over the past few years – not least the wholesale re-vamping of the tax treatment of carried interest and other fund participations for investment fund managers – the UK...more
3/15/2017
/ Carried Interest ,
Corporate Taxes ,
Domicile ,
Double Taxation ,
HMRC ,
Investment Funds ,
Investment Management ,
Limited Liability Partnerships ,
National Insurance Contributions ,
Partnerships ,
Passporting ,
Self-Employment Tax ,
Tax Reform ,
Tax Treaty ,
UK ,
Withholding Tax