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
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
4/20/2018
/ Asset Management ,
BEPS ,
Corporate Taxes ,
Cross-Border ,
Cryptocurrency ,
Customer-Loyalty Programs ,
Cybersecurity ,
Derivatives ,
EU ,
Financial Conduct Authority (FCA) ,
Financial Services Industry ,
MiFID II ,
MiFIR ,
UK ,
UK Brexit
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
12/13/2017
/ Asset Management ,
Cyber Attacks ,
Cybersecurity ,
Data Breach ,
EMIR ,
EU ,
European Central Bank ,
European Supervisory Authorities (ESAs) ,
Financial Conduct Authority (FCA) ,
Hackers ,
Investment Management ,
Jurisdiction ,
Regulatory Oversight ,
UK ,
Variation Margin Requirements (VM)
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
A compact summary of the most recent regulatory and tax developments relevant to the UK asset management industry. This issue includes details on ESMA’s updated Q&As on the key information document requirements for PRIIPs;...more
11/29/2017
/ Autumn Statement ,
Commercial Real Estate Market ,
Corporate Taxes ,
Derivatives ,
EMIR ,
EU ,
EU Market Abuse Regulation (EU MAR) ,
European Securities and Markets Authority (ESMA) ,
Hedge Funds ,
HMRC ,
IOSCO ,
Key Information Document (KIDs) ,
Legal Entity Identifiers ,
MiFID II ,
Money Market Funds ,
Non-Resident Income Taxes ,
Over The Counter Derivatives (OTC) ,
Packaged Retail And Insurance-Based Investment Products (PRIIPS) ,
Real Estate Investments ,
Tax Reform ,
UK
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
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
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
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
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
7/2/2016
/ CFCs ,
Controlled Foreign Corporations ,
Corporate Taxes ,
Customs ,
Dividends ,
EU ,
European Economic Area (EEA) ,
Exit Tax ,
ICAV ,
Income Taxes ,
International Tax Issues ,
Referendums ,
Stamp Taxes ,
Tax Treaty ,
Transfer Pricing ,
UK ,
UK Brexit ,
Value-Added Tax (VAT)
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
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
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 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 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
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
10/10/2015
/ Anti-Avoidance ,
Budgets ,
Capital Gains ,
Carried Interest ,
Carried Interest Tax Rates ,
Corporate Taxes ,
Cost-Shifting ,
Double Taxation ,
HMRC ,
Investment Management ,
Private Equity ,
Resident Non-Domiciled (RND) ,
Tax Credits ,
UK
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
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
7/16/2015
/ Anti-Avoidance ,
Budgets ,
Capital Gains ,
Carried Interest ,
Corporate Taxes ,
HMRC ,
Investment Management ,
Private Equity ,
Resident Non-Domiciled (RND) ,
Tax Reform ,
UK
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
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
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
This year’s Autumn Statement delivered by the Chancellor of the Exchequer in Parliament on 5 December 2013, and the subsequent draft Finance Bill and H.M. Revenue & Customs (HMRC) and H.M. Treasury press releases of 10...more
12/27/2013
/ Alternative Investment Fund Managers Directive (AIFMD) ,
Alternative Investment Funds ,
Deferred Compensation ,
Hedge Funds ,
International Finance ,
Investment Funds ,
Offshore Funds ,
Partnerships ,
Payment-In-Kind ,
Private Equity Funds ,
UK
Background -
HMRC published a consultation document on 20 May 2013 which proposed major changes to the taxation of partnerships. This was of particular relevance to investment management LLPs – and especially to those...more
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