This site uses cookies. and this alert will appear once and then not again.

Keeping Up With Alternative Investment Funds ("KUWAIF") Newsletter - November edition

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.

Keeping Up With Alternative Investment Funds ("KUWAIF") Newsletter - October edition

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.

Keeping up with Alternative Investment Funds - September 2019

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.

Profit fragmentation – Finance Bill update

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.

Profit fragmentation – draft legislation

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.

Taxation of partnerships in the UK

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.