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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

IR35 Reforms Postponed

Reforms to the off-payroll working rules (known as IR35) have been postponed until 6 April 2021 in order to reduce pressure on private sector organisations after the COVID-19 outbreak....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

Termination Payments - Changes to the taxation of UK termination payments

In this OnPoint, we report on two changes to the taxation of termination payments to departing employees of which employers need to be aware – first, the levying with effect from 6 April 2020 of employer’s national insurance...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

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 - Third Quarter 2017: Global Update: UK Criminal Finance Act 2017: Immediate Considerations...

UK asset managers, non-UK asset managers carrying on business in the UK and the funds they manage are within the scope of the new corporate criminal offences of failing to prevent the facilitation of tax evasion. As the new...more

HMRC Publishes Guidance on the Tax Treatment of Clawback of Remuneration in the UK

Since the financial crisis of 2008 / 2009, swathes of new regulations have been introduced governing various aspects of remuneration in the financial services sector. A key feature of these rules is the compulsory clawback of...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

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

Government Set to Overhaul Taxation on Termination Payments

Currently, non-contractual compensation payments made solely on account of termination of an individual’s employment enjoy a favourable tax treatment in two respects – the payment can be made without deduction of income tax...more

Brexit – The UK and International Tax Consequences

The political, economic and constitutional fallout of the UK’s referendum decision to leave the European Union (Brexit) will continue for some time. In addition to considering some of the possible domestic UK tax implications...more

UK Taxation Update for Investment Managers

The shifting sands of the taxation landscape for investment managers continues apace. Just when you perceive an oasis of stability on the horizon, it is revealed to be a mirage by the announcement of yet further changes....more

New Withholding Tax Exemption for Private Placements in the UK

Interest paid by UK companies is generally subject to withholding tax at 20%. Although various exemptions apply, most notably in respect of interest payments to banks and other UK companies, and in respect of securities...more

Financial Services Quarterly Report - Fourth Quarter 2015: Further Change to the UK Taxation of Carried Interest

The UK Government, as anticipated, issued draft legislation on 9 December designed to establish clear rules as to when carried interest can qualify for favourable capital gains tax treatment. The draft legislation follows a...more

Further Change to the UK Taxation of Carried Interest

The UK Government, as anticipated, issued draft legislation on 9 December designed to establish clear rules as to when carried interest can qualify for favourable capital gains tax treatment. The draft legislation follows a...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

UK tax treatment of US LLC: HMRC’s practice following Anson

We reported earlier this year on the UK Supreme Court’s decision in HMRC v Anson, in which it was held that a UK taxpayer, Mr. Anson, was entitled to claim relief against his UK tax liabilities for US tax paid on his share of...more

Taxpayer wins landmark decision regarding the UK tax treatment of US LLCs

Following the taxpayer’s victory in the recent Supreme Court decision of HMRC v Anson, UK resident members of Delaware LLCs may now be entitled to claim relief against their UK tax liabilities for US tax paid on their share...more

Changes to the UK Tax Residence Rules for AIFs and Pitfalls to Avoid

In a previous article, we reported that draft legislation had been published to extend the scope of section 363A of the Taxation (International and Other Provisions) Act 2010 to ensure that alternative investment funds (AIFs)...more

UK Enters into Tax Agreements with the Cayman Islands and Other Offshore Jurisdictions

The UK and the Cayman Islands recently entered into an agreement to improve international tax compliance (ITC). Similar to the US Foreign Account Tax Compliance Act (FATCA), the ITC imposes wide-ranging UK financial reporting...more

HMRC Consults on Tax Residence of Non-UCITS Funds Managed by UK Managers

HMRC has released a series of consultations regarding financial services taxation. The proposed measures are in line with the Government’s “UK investment management strategy”, a commitment announced in the 2013 Budget to...more

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