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International Comparative Legal Guide – Private Equity 2024

For the sixth consecutive year, Dechert is the contributing editor of the International Comparative Legal Guide - Private Equity. The guide, now in its tenth edition, is one of the most comprehensive comparative guides to...more

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

ATAD 3 (Shell Companies) – Potential Implications for Fund Structures

A draft EU Council directive, known as ATAD 3, was issued by the European Commission as a proposal at the end of last year. The directive is aimed at countering the misuse of 'shell' entities and could impose adverse tax and...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

UK Qualifying Asset Holding Companies: How Will the Proposals Impact Debt Funds?

The structure is a simplified version of how a typical European fund might be established in Luxembourg where currently we would typically use a downstream Luxembourg SARL or securitisation vehicle as the intermediate...more

UK Life Sciences and Healthcare Newsletter - March 2021: Granting Incentives Under U.S. Plans to UK-based Executives

One of the most effective ways to incentivise staff, in particular senior employees, is to offer them the opportunity to purchase stock or shares in a group company. U.S. companies often operate stock and other incentive...more

UK Life Sciences and Healthcare Newsletter - March 2021: Future Fund: Breakthrough

Following the successful run of the government-backed Future Fund, the British Business Bank has announced that it is set to launch a further fund for development, Future Fund: Breakthrough. This scheme is set to provide up...more

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

UK Asset Holding Companies – Alternative Credit Funds: A Chance to Shape the Future

The UK government has published a response to the consultation announced last year in relation to the possible introduction of a new tax advantaged regime for UK asset holding companies (AHC) used in the context of...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

Private Equity in the United Kingdom - 2020 Edition

Dechert partnered with Getting the Deal Through and Law Business Research on their annual Market Intelligence Private Equity Guide. The 2020 Guide invites leading practitioners to reflect on evolving legal and regulatory...more

UK Life Sciences and Healthcare Newsletter - December 2020: Market News

Recent notable industry transactions. The Alan Turing Institute, the Royal Statistical Society and the UK Department of Health and Social Care's Joint Biosecurity Centre finalised a partnership agreement in relation to the...more

UK Life Sciences and Healthcare Newsletter- December 2020: Regulatory Updates

Medicines and Medical Devices Bill (MMDB) – The MMDB is intended to act as the primary UK legislation specifying powers that would enable the regulatory regimes for human medicines, clinical trials, veterinary medicines and...more

UK Life Sciences and Healthcare Newsletter - December 2020: A Brief Update on the EMI Scheme

As the most tax advantageous HMRC approved share option scheme available, the Enterprise Management Incentive (EMI) scheme has long been the preferred form of incentive for eligible early and mid-stage UK-based life science...more

UK Life Sciences and Healthcare Newsletter - December 2020: The UK National Security and Investment Bill

The UK has announced a bill proposing a new system to screen transactions for national security risk, separate from the system of merger review operated by the Competition and Markets Authority. The National Security and...more

The UK Government Furlough Scheme: Time to Reconcile

The Coronavirus Job Retention Scheme - On 26 March 2020, the UK Government announced the Coronavirus Job Retention Scheme (“the Furlough Scheme”). The Furlough Scheme was designed to protect the UK economy by assisting...more

DAC6: Approval of six month extension to the reporting timetable

On 24 June, the Council of the European Union formally adopted a directive giving EU Member States the option to defer by six months the timetable for reporting under DAC6. ...more

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