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United Kingdom Capital Gains HMRC

Proskauer - Tax Talks

Taxing carried interest in the UK: the new regime announced in the Labour government’s Autumn Budget 2024

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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

Goodwin

A Token of Appreciation: Cryptoassets and Employee Incentives - a UK Tax Primer

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Businesses in the blockchain and cryptoasset space are increasingly looking to utilise digital currency and other cryptoassets as an alternative to or alongside other, more traditional employee incentive arrangements, such as...more

Cadwalader, Wickersham & Taft LLP

An option to dispose of property does not necessarily give rise to a taxable disposal

In the appeal case of Krishnamohan v HMRC [2024] UKFTT 346, the UK’s First-Tier Tribunal (“FTT”) determined that an agreement titled “Option Agreement” that was entered into to dispose of certain properties, does not, for...more

Proskauer Rose LLP

UK Tax Round Up - December 2023

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Welcome to December’s edition of our UK Tax Round Up. This month has seen two interesting decisions on the connections needed for amounts to be taxed as employment income, the latest instalment in the BlueCrest partner...more

Skadden, Arps, Slate, Meagher & Flom LLP

Activists Assemble: Recent Trends in Activist Campaigns Targeting UK Investment Trusts

The United Kingdom has long been a target destination for activist investors. It is the venue for nearly half of all of recent activist campaigns in Europe. In previous articles, we have discussed how informed boards should...more

Hogan Lovells

Carried interest: legal challenge to the UK tax treatment

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Recent publicity around the UK taxation of carried interest may, in due course, make it more likely that a UK government would look again at the tax rules around carried interest. ...more

Proskauer Rose LLP

UK Tax Round Up - May 2023

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Welcome to May’s edition of our UK Tax Round. This month has been relatively quiet but there were a couple of cases that affect transactions that we see in practice, including an interesting update on what could constitute a...more

Cadwalader, Wickersham & Taft LLP

UK Budget 2023 – Key Tax Measures

The Chancellor of the Exchequer delivered the United Kingdom (“UK”) Budget for 2023 on 15 March 2023. The Budget was delivered against a backdrop of some familiar political headwinds, caused by the lengthy shockwaves of...more

Proskauer Rose LLP

UK Tax Round Up - November 2022

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Welcome to the November edition of the UK Tax Round Up. This month has seen the new Chancellor deliver his Autumn Statement following from the previous Chancellor’s so-called mini budget in October and the Court of Appeal’s...more

Proskauer Rose LLP

UK Tax Round Up - January 2021

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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

BCLP

Private Wealth - Horizon Scanning 2020

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With a number of changes affecting the private wealth world to come over the next 12 months, our private client team take a look at some of the key UK legal developments for 2020, including the extension of the UK trust...more

BCLP

HMRC updates its guidance on the taxation of cryptoassets in the UK

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On 20 December 2019 HMRC updated its guidance on the taxation of cryptoassets. In particular, HMRC has now given its view on where the most common form of cryptoasset (being the exchange token) should be treated as located...more

Proskauer Rose LLP

UK Tax Round Up - April 2019

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UK Case Law Developments - Damages on share sales same as on other sales - In Oversea Chinese Banking Corporation Ltd v ING Bank NV, the Commercial Court has held that the measure of damages for breach of warranty in...more

Proskauer Rose LLP

UK Tax Round Up - March 2019

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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

Katten Muchin Rosenman LLP

Potentially Helpful Changes to Entrepreneurs' Relief

The UK Government has recently proposed further changes to the Entrepreneurs' Relief rules which could make it easier to obtain Entrepreneurs' Relief in certain cases....more

Katten Muchin Rosenman LLP

UK to Tax Real Estate Capital Gains of Non-UK Investors

On 6 July 2018, the UK Government published draft legislation to extend the territorial scope of UK tax by bringing capital gains realised by non-UK resident investors from UK real estate within the scope of UK taxation with...more

Proskauer - Tax Talks

UK Finance Bill 2019 published – UK commercial property tax regime for non-resident investors to change, but some relief for...

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On 6 July 2018 the UK Finance Bill 2019 was published by the UK Government. The draft Finance Bill contains the details of the new regime on taxation of non-UK resident investors in UK real estate that had been proposed in a...more

Proskauer Rose LLP

UK Tax Round Up - March 2018

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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

Cooley LLP

Alert: Temporary Halt on Grant of EMI Options to UK Employees

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With a generous individual limit of £250,000, companies with a UK presence, group gross assets below £30m (balance sheet test) and fewer than 250 employees often grant potentially tax advantageous Enterprise Management...more

Proskauer Rose LLP

UK Tax Round Up - August 2017

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UK Tax News and Developments - Latest on the Finance (No 2) Bill 2017 - On 20 July 2017 the government announced in Hansard that the House of Commons will, on Wednesday 6 September 2017, be asked to approve the Ways and Means...more

Proskauer Rose LLP

Tax Round Up - June 2017

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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

Proskauer - Tax Talks

Proposed New UK Penalties Regime Precipitated by CRS

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Many people will be familiar with the information gathering and reporting requirements the OECD’s Common Reporting Standard (“CRS”) places on financial institutions. The first exchanges of information between tax authorities...more

McGuireWoods LLP

Further Changes Announced to the Non-Domiciles Regime

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On 19 August 2016, the UK Government published a new consultation paper together with draft legislation which will affect changes to the non-domiciles (“non-doms”) regime in the UK. The proposals will be legislated...more

Skadden, Arps, Slate, Meagher & Flom LLP

"No Gains, Just Pain: Increasingly Uncomfortable Taxation Environment for Private Equity Executives’ Compensation"

Arguing that their compensation should count as capital gains — since it derives from the appreciation in value of portfolio companies — private equity executives in Europe generally have been taxed under the more favorable...more

Dechert LLP

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

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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

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