Alternative Investment Funds

Welcome to our September edition of Keeping Up With Alternative Investment Funds ("KUWAIF") newsletter.

Welcome to our June edition of Keeping Up With Alternative Investment Funds ("KUWAIF") newsletter.

Welcome to our April edition of Keeping Up With Alternative Investment Funds ("KUWAIF") newsletter.

Welcome to our February edition of Keeping Up With Alternative Investment Funds ("KUWAIF") newsletter.

Welcome to our December edition of Keeping Up With Alternative Investment Funds ("KUWAIF") newsletter.

Welcome to our October edition of Keeping Up With Alternative Investment Funds ("KUWAIF") newsletter.

This edition of Keeping up with Alternative Investment Funds covers a large variety of topics, including the following: - UK Digital Assets consultations and announcements – update for - Alternative Asset Managers - US Foreign Tax Credit Regulations and the New Limitations Potential Impact for AIFs - Achieving Scale – moving the operating model from artisan to industrial - The new UK-Luxembourg double tax treaty and its impact on UK real estate holdings - UK Economic Crime Act deadlines - Hungarian financial transaction tax on cross-border services

Welcome to our June edition of Keeping Up With Alternative Investment Funds ("KUWAIF") newsletter.

Welcome to our May edition of Keeping Up With Alternative Investment Funds ("KUWAIF") newsletter.

Welcome to our April edition of Keeping Up With Alternative Investment Funds ("KUWAIF") newsletter.

Welcome to our March edition of Keeping Up With Alternative Investment Funds ("KUWAIF") newsletter.

Welcome to our February edition of Keeping Up With Alternative Investment Funds ("KUWAIF") newsletter.

Welcome to our January edition of Keeping Up With Alternative Investment Funds ("KUWAIF") newsletter.

Welcome to our December edition of Keeping Up With Alternative Investment Funds ("KUWAIF") newsletter.

This edition of Keeping up with Alternative Investment Funds covers a large variety of topics, including the following: 1) Introduction of the Health and Social Care Levy; 2) European Commission's initiative to introduce a new system for withholding taxes; 3) Complying with employment tax requirements - Learnings from recent public sector IR35 settlements; and 4) Denmark - Update on Withholding Tax Reclaims.

This edition of Keeping up with Alternative Investment Funds covers a large variety of topics, including the following: 1) Taxation of UK asset holding companies in alternative fund structures; 2) Sustainable Investment and the ESG Landscape - Keeping on-side of UK Regulation; 3) ESG and Carried interest; and 4) Uncertain tax treatment reporting.

Welcome to our July edition of Keeping Up With Alternative Investment Funds ("KUWAIF") newsletter. Topics covered include: 1) CJEU’s K and DBKAG Judgement; 2) Why the UK Corporate Criminal Offence rules should still be high on the agenda for Alternative Investment Fund Managers; 3) EU business tax communication; 4) Global operational taxes update; and 5) Long term asset funds - Worth the wait?

Welcome to our June edition of Keeping Up With Alternative Investment Funds ("KUWAIF") newsletter.

Welcome to our May edition of Keeping Up With Alternative Investment Funds ("KUWAIF") newsletter.

Welcome to our April edition of Keeping Up With Alternative Investment Funds ("KUWAIF") newsletter.

Welcome to our March edition of Keeping Up With Alternative Investment Funds ("KUWAIF") newsletter.

Welcome to our Keeping Up With Alternative Investment Funds (“KUWAIF”) summary of the UK’s first ever ‘Tax Day’. We hope you find this summary interesting and should there be any areas you would like to discuss, please do get in touch with your PwC contact.

Welcome to our February edition of Keeping Up With Alternative Investment Funds ("KUWAIF") newsletter.

Welcome to our January edition of Keeping Up With Alternative Investment Funds ("KUWAIF") newsletter.

Welcome to our December edition of Keeping Up With Alternative Investment Funds ("KUWAIF") newsletter.

Welcome to our November edition of Keeping Up With Alternative Investment Funds ("KUWAIF") newsletter.

Welcome to our October edition of Keeping Up With Alternative Investment Funds ("KUWAIF") newsletter.

Welcome to our September edition of Keeping Up With Alternative Investment Funds ("KUWAIF") newsletter.

Welcome to our August edition of Keeping Up With Alternative Investment Funds ("KUWAIF") newsletter.

Welcome to our July edition of Keeping Up With Alternative Investment Funds ("KUWAIF") newsletter.

Welcome to our June edition of Keeping Up With Alternative Investment Funds ("KUWAIF") newsletter.

Welcome to our May edition of Keeping Up With Alternative Investment Funds ("KUWAIF") newsletter.

Welcome to our April edition of Keeping Up With Alternative Investment Funds ("KUWAIF") newsletter.

We are pleased to attach the March edition of Keeping up with Alternative Investment Funds.

We are pleased to attach the February edition of Keeping up with Alternative Investment Funds.

We are pleased to attach the January edition of Keeping up with Alternative Investment Funds.

This edition of Keeping up with Alternative Investment Funds covers a large variety of topics, including the following: 1) Non-resident capital gains tax update; 2) LIBOR reform - impact on the tax affairs of Alternative Investment Funds; 3) IR35 - 4 months to go; 4) HMRC's focus on Offshore Funds; and 5) Smooth moves - using capital allowances and business rates to your advantage on an office move project.

This edition of Keeping up with Alternative Investment Funds covers a large variety of topics, including the following: 1) HMRC enquiries on Disguised Investment Management Fees (“DIMF”) and carried interest; 2) EU MDR - Time for action; 3) How can you manage the risks arising from the changing tax transparency landscape? 4) Business Risk Review - the new approach from 1 October 2019; and 5) Dutch 2019 budget day - Tax package.

This edition of Keeping up with Alternative Investment Funds covers a large variety of topics, including the following: 1) Investment Firms Directive - remuneration implications; 2) LIBOR impact and transition; 3) Corporate capital loss restriction for corporation tax; 4) Non-resident capital gains tax – an update; 5) Upper tribunal decision on corporate residence; and 6) EU MDR - Hallmark 1.

The first edition of 'Keeping up with alternative Investment Funds' which includes our latest thoughts on topical issues that are affecting the Alternative Investment Funds industry, brought to you by our extensive network of industry and subject matter experts both in the UK and further afield.

Faced with uncertainty in their business as a result of Brexit, Asset & Wealth Managers (‘AWMs’) should consider the potential impact of the tax drag on their funds’ investments. Have you considered how your fund may be impacted as a result of increased post Brexit tax charges?

What is the Temporary Permissions Regime?When does the Temporary Permissions Regime come into effect? How long will a temporary permission be?

In the event of a ‘no deal’ Brexit, the UK would become a third country and UK financial services firms would lose their passport rights and access to the single market for financial services.

What is happening in the coming weeks at a political level? What do the meaningful vote outcomes mean for AWMs? Are AWMs able to rely on Article 50 being cancelled and the Brexit process being halted? What does a ‘no-deal’ Brexit mean for AWMs?

Substantial changes have been made to the profit fragmentation anti-avoidance since the original consultation was published. These rules apply to both individuals and corporates from April 2019. Businesses, including partnerships, with international aspects should consider whether they may apply and, if so, whether they need to take action.

EU Mandatory Disclosure Rules came into force on 25 June 2018 . This regime requires the reporting of certain cross-border arrangements that meet certain hallmarks. The rules are very broad so we expect that some disclosures will need to be made.

The new anti-avoidance rules on profit fragmentation apply from April 2019. They are designed to target abusive arrangements but the draft legislation is much wider. We believe that many normal businesses may need to notify HMRC of arrangements involving overseas entities under the new rules, even if it is clear that no extra tax will ultimately be due. We have brought this to HMRC’s attention but it is unlikely that any industry specific exemptions will be introduced.

When raising a new fund, one of the first questions to address is what’s the best structure? There are many moving parts to reaching a decision, not just concerned with tax!

The tax considerations surrounding co-investment changed significantly following the introduction of the Disguised Investment Management Fee (“DIMF”) legislation, which came into effect from 6 April 2015.

Changes to the tax rules mean that there are now strict methods to determine how UK investment managers are taxed on their income, gains and carried interest.

Members or UK limited liability partnerships (“LLP”) are taxed differently to employees. This resource sets out the basis on which profits are taxed, including in the opening years.

It is important to establish a fund vehicle that is subject to minimum taxation at the level of the fund and relatively simple to administer.

The salaried member rules are designed to ensure that LLP members who are essentially providing “employment-like” services are treated as “employees” for tax purposes.

The changes to the taxation of UK resident non-domiciled (“UK RND”) individuals came into effect from April 2017 and will impact the personal tax treatment of long term UK residents, as well as the some offshore structures such as trusts.

Most Private Equity funds include partnerships somewhere in their structure. Although for most relevant UK tax purposes the partnership is treated as tax transparent the tax rules associated with how profits should be shared should be important to many Private Equity managers.

This guide provides an overview of the UK self-assessment system for self-employed individuals and partners who are required to file UK tax returns.