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Last year our work involved over 75 jurisdictions.
Insights into the regime
Our latest monitor of UK, EU and OECD tax policy changes relevant to relevant to private capital managers.
UK, EU & OECD tax monitor
All content © 2022 Macfarlanes LLP. All rights reserved.
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The natural choice
Macfarlanes tax
Our latest monitor of UK, EU and OECD tax policy changes relevant to private fund managers.
UK, EU and OECD tax monitor
A forum for those working in the private funds industry to keep track of tax developments and market practice, share insights and network with each other.
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The QAHC Regime
The QAHC regime
Our latest monitor of UK, EU and OECD tax policy changes relevant to private capital managers.
Join David Gauke and Rhiannon Kinghall Were as they break down the tax headlines and implications for clients
Autumn Statement 2023 podcast – tax
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A refresher on the ERS rules
30 Jun 2022
Members exclusive
Managing portfolio company tax risks and preparing for an exit
16 Jul 2022
Continuation fund session
01 Aug 2022
Where we are in terms of SMR and awarding equity
10 Aug 2022
AHC session
21 Sept 2022
Developments in credit fund structuring and areas of investor focus
25 Sept 2022
Latest insights
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This document sets out the additional consideration to bear in mind when making a minority private equity investment.
By March Petch 10 Nov 2020
Minority investment tax protections
A common question that we see asked relates to the length of time that HMRC has to raise an enquiry or assessment, as well as the circumstances.....
By Bezhan Salehy 07 Dec 2020
HMRC assessment powers
In Europe the approach by tax authorities to relief from withholding taxes is continuing to evolve following the rulings on the so-called Danish beneficial....
By Maudie Leach 21 Jan 2021
WHT relief in Europe
The EC has published a consultation looking to tackle the use of shell entities in the EU.
By Rhiannon Kinghall Were 15 June 2021
ATAD 3 to tackle use of shell entities
The public consultation on the draft Directive to tackle the misuse of shell entities (ATAD 3) closed this week.
By Rhiannon Kinghall Were 08 Apr 2022
ATAD 3 consultation response
Note setting out a brief summary of some of the key UK tax points to be aware of when undertaking a lender-led debt restructuring, covering debt waivers.....
By Joe Robinson 13 January 2022
Our HMRC consultation responses
Podcast on offshore funds rules
FAQs
Salaried member rules following Bluecrest
By Forename Surname Day month year
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Global tax policy monitor
Global tax monitor (gated)
Video: Offshore funds rules
In our regular tax policy monitor find out about the latest updates pertinent to private fund managers from a range of jurisdictions.
In this short video we explain the offshore fund rules and set out some structural solutions to navigate the rules.
Primer to help you understand how the rules could apply to your funds.
Podcast: Offshore funds rules
Tax policy updates pertinent to private fund managers from a range of jurisdictions.
A collection of the latest policy developments impacting private fund managers.
In this note, we set out an overview of the valuation methods which we use in practice, and explain when and why each is appropriate.
Carried interest valuation considerations
Salaried member rules following BlueCrest
A note summarising the key points in relation to the Upper Tribunal’s decision in the BlueCrest case.
A note which breaks down the meaning of each of the most commonly used terms, including a description of which fund types and/or investor types they may be relevant to in relation to US taxes.
Guide to US tax terms
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27 September 2022
A collection of the latest policy developments, including consultations, responses and dialogue with government, impacting private fund managers.
Date Month Year
The spring 2022 edition of our global tax policy monitor has now been published. It features tax policy updates pertinent to investment managers from a range of jurisdictions including; Australia, China, France, Germany, India, Italy, Japan, Singapore, Sweden, UK, EU and OECD.
Global tax monitor
The UK’s offshore funds rules have always been relevant to private funds using corporate investment holding structures, but have not always been a focus for firms and can be overlooked. In this short video we explain the rules; consider how they are relevant to PETF funds and their management teams; and set out some structural solutions and exemptions that can help mitigate negative tax consequences of the rules.
The salaried member rules in the investment management in-dustry following BlueCrest: the $100m answer. The salaried member rules (SMR) have been in force since April 2014 and have been the source of much angst to those operating as limited liability partnerships (LLPs) within the investment management industry since then.
Unfortunately, the rules governing HMRC’s assessment powers and secondary liability for tax can be complicated, are located in different parts of the tax code, and differ depending on the tax in question. This can make it difficult to come to a definitive answer on what might be thought to be a relatively simple question.
Guide to the taxation of carried interest, covering what we mean by "carried interest", how it is taxed, DIMF, the carried interest rules, income-based carried interest, and awarding carry to executives and new joiners. Includes flow chart for working out how the different rules apply and interact.
FAQ: taxation of carried interest
FAQs on the disguised investment management fee (DIMF) regime, including when the rules apply, when the rules treat amounts as co-invest or carried interest, how the rules apply to non-doms, and understanding key terminology. Also includes a chronology of the DIMF and carried interest regimes.
FAQ: DIMF rules
Guide to reporting requirements under the employment related securities regime in ITEPA 2003.
FAQ: ERS reporting requirements
Answers to a range of frequently asked questions on section 431 elections, including why to make an election, whether they are required for NEDs and non-UK residents, questions around timing and procedure, application to carried interest and LLP members, and a brief summary of US 83(b) elections.
FAQ: Sections 431 elections
A collection of our responses to recent consultations on the latest policy developments impacting private fund managers.
Consultation responses (gated)
A guide to the reporting requirements under the employment related securities (ERS) regime.
Guide to ERS reporting requirements (gated)
A guide to section 431 elections explaining the circumstances when an election is needed, considerations around NEDs and non-UK resident employees, the application to carried interest and administrative issues.
FAQs: Section 431 elections
Pillar Two
QAHC
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DIMF, carry and reward
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Transaction structuring
HMRC enquiries and tax risk management
VAT
Valuations and financial modelling
Employment tax and mobility
Fund formation and fund tax issues
Coming soon
In this note, we set out an overview of the valuation methods which we use in practice.
A note summarising the key points arising from the decision in the BlueCrest case.
A note which breakdowns the meaning of each of the most commonly used terms, including a description of which fund types and/or investor types to whom they may be relevant in relation to US taxes.
DIMF, carry, co-invest and reward
International tax developments
Restructurings and MIP resets
QAHCs and Luxcos
Policy in practice: Autumn Statement 2023 podcast – tax
PETF events: access all member event materials from 2020 to 2023
Special Purpose Acquisition Companies are being seen more and more in our practice. In this session, Rob Collard, Alex Ereira and Janic Luo give an overview of what SPACs are, how they operate, the typical features we see, and how they are used for IPOs. We also discussed the employment tax and valuation considerations relating to SPACs, and the UK tax considerations more generally.
24 February 2021
SPACs: key legal, tax and valuation considerations
To start the year we set out the key tax issues investment managers would need to have on their agenda in 2021 reflecting the big picture developments set by the OECD and the EU, and informed by Covid-19, Brexit and other reforms. A selection of UK specific investment fund issues like anti-hybrids rules and the UK asset holding company regime, as well as wider developments such as IR35 and uncertain tax positions were covered.
Wednesday, 20 January 2021
2021 Horizon Scanning
In this session, we ran through the new HMRC consultation on UK asset holding companies, namely the Government's proposal to introduce a new elective regime for qualifying asset holding companies with targeted tax reliefs. We reviewed a timeline of the consultation, and discussed the summary of responses to the first round of the consultation. The session covered eligiblity criteria, gain exemptions, deductions and transfer pricing, as well as other specific issues. We also garnered input for the formal response to the consultation due to be submitted in February. This session was aimed at PE and Credit houses who are considering utilising the AHC regime.
Thursday, 28 January 2021
AHC update
Hedging FX risk is an important consideration for internal funding arrangements at a fund level and external and shreholding debt financing in deals. We discussed the regulatory and tax issues that can arise in these situations and ways to mitigate unforseen exposure.
Wednesday, 03 February 2021
Understanding FX hedging and its tax consequences in a fund/deal context
How people work changed significantly during the Covid-19 lockdown, and continues to change. With more people working from home, and permanent establishment risk being increased due to individuals being unable to travel, in this session we discussed how the 'modern workplace' has impacted individuals and companies from a tax perspective, and what businesses should be doing to manage the associated risk. We also discussed IR35 and the practical steps for businesses to consider taking to prepare for this.
Wednesday, 10 February 2021
Employment tax and mobility issues post-Brexit and Covid (and IR35)
There are several areas of complexity which come up when determining if, and when, the employment-related securities rules apply to self-employed individuals. In this session, Mark Baldwin and Alicia Thomas address the key questions, including how the rules apply to LLP members, their application to awards of carry and shares, and the application of anti-avoidance rules in this area.
Wednesday, 17 February 2021
ERS rules for the self-employed
Wednesday, 24 February 2021
Tax governance is increasingly seen as a core part of the "G" (governance) in ESG. In this session we covered the ESG landscape, the evolution of tax within ESG and showcased our tool to help managers prepare for investor queries; engage portfolio companies to pre-empt DD questions; and assess house level governance and risk issues.
Wednesday, 10 March 2021
Where tax risk management meets ESG – fund manager and portfolio company considerations
There are a range of operational issues involved in adminstering a carried interest arrangement, which Damien Crossley and Ceinwen Rees surveyed in this session. They discussed best practice on inception, award, and distribution, and also considered the implications of carried interest holders leaving a firm or moving to another country.
Wednesday, 17 March 2021
Carried interest – managing operational risk
Following the launch of our global tax policy monitor we provided an update on recent international tax changes to keep you abreast of critical international tax developments from the EU, OECD and a number of other jurisdictions.
Wednesday, 24 March 2021
Continuation funds
In this session our VAT team explored the impact of Brexit, covering the treatment of supplies to EU passive holding companies, when FS supplies carry a right to recover, and changes to existing partial exemption special methodologies (PESMs). We also discussed several VAT policy consultations announced by HMRC on Tax Day 2021.
Tuesday, 30 March 2021
VAT update
Following government consultation to update the UK's anti-hybrid rules, we explored the Finance Bill 2021 changes that introduced a number of easements in their application to fund structures. A series of practical examples were provided.
Wednesday, 21 April 2021
Revised UK anti-hybrid rules
In response to the government's introduction of a new reporting requirement for large businesses to notify HMRC of uncertain tax positions, we explored the applicability of this regime to the private equity industry and shared our thoughts on the key areas where notifications might be required (e.g. VAT, transfer pricing, and DIMF) if a PE house was caught within the scope of the rules.
Thursday, 20 May 2021
Uncertain tax positions
In advance of the introduction of the Long Term Asset Fund, Lora Froud and Alicia Thomas discussed the key features of the regime and examples of where it might be seen in practice. A number of practical points were shared around the criteria, eligible assets, and governance of the regime, as well as what it would mean having an LTAF as an investor in your fund.
Thursday, 27 May 2021
LTAF
Special Purpose Acquisition Companies - or "SPACs" - have been one of the most prominent innovations in public markets in recent years. While the trend began in the US we have also seen SPACs emerge in Europe too. In this session Damien Crossley, Rob Collard and Janice Luo consider the tax and structuring issues facing European SPACs.
Thursday, 17 June 2021
European SPACs
Thursday, 08 July 2021
Introducing our new global policy monitor – tax developments impacting investment fund managers in key financial centres
As the UK Asset Holding Company regime develops we shared the key things we had learnt about the regime following the publication of draft legislation and highlighted the critical changes needed to ensure an effective regime.
Thursday, 22 July 2021
Update on AHC draft legislation
Flexible working across borders raises a range of employment tax and VAT considerations, which we examined in this session.
Wednesday, 22 September 2021
Moving executives into and out of the UK
In this session we explored different carry models for deal by deal pay out models, explaining the advantages and disadvantages of the various approaches and highlighting traps for the unwary.
Thursday, 07 October 2021
Deal-by-deal carry
Covid-19 significantly disrupted many businesses. In this session we surveyed the potential implications of this for PE businesses' transfer pricing, and considered how HMRC's approach to identifying transfer pricing risk is evolving.
Wednesday, 20 October 2021
Managing transfer pricing risk
Following the publication of detailed draft legislation we examined the conditions for entry into the Asset Holding Company regime specifically highlighting the challenges and complexity arising from the ownership condition. We also explored the implications for remittance basis users and the operational aspects of the regime.
Monday, 08 November 2021
AHC: what you need to know about the latest draft legislation
In this session our corporate advisory team provided an update on the latest developments in accounting, regulation and valuations - including changes to carried interest accounting, the introduction of IFPR and ESG reporting.
Thursday, 18 November 2021
Financial year end considerations
Managing PE risk in a fund context is important. In this session we covered the basics around PEs and shared a number of examples to illustrate the risks and how you can manage the exposure.
Thursday, 02 December 2021
Managing permanent establishment risks for the fund as a result of non-UK operations
Tax distributions are an important consideration for any fund that has US-resident carried interest holders. In this session we reviewed why tax distributions are necessary, the commercial considerations when writing them into a fund agreement, and examined the UK tax issues they can give rise to.
Thursday, 09 December 2021
US tax distributions
Become a PETF member to view our previous event resources.
2020
2021
2022
2022 looks set to be a pivotal year for the international tax system. Following the publication of the OECD’s Pillar Two model rules to bring in a global minimum tax we shared our thoughts on the application and implications for the PE industry from a house, fund and portfolio perspective.
10 February 2022
Overview of OECD Pillar Two model rules
Our VAT team shared their thoughts on the VAT opportunities that have emerged since the UK left the EU. They addressed changes to the VAT recovery profiles of firms managing UK funds as well as new avenues for cross-border deal structuring and covered the common questions they are asked in light of Brexit.
24 February 2022
As tax advisers, we and our clients are often focused on the latest technical developments and innovative ideas to optimise fund and house structures. In practice, however, the operation of fund structures come with unique challenges. In this session we considered some of the common operational tax challenges and how to manage them, such as the challenges of US reporting obligations for non-US funds and managing the investor tracking requirements thrown up by BEPS and FATCA/CRS.
10 March 2022
Operational tax update
The application of the DIMF, IBCI and carried interest rules continues to throw up new issues. In this session we provided an update on DIMF and carry issues that have arisen in practice recently and some of the points we are seeing in HMRC disputes.
22 March 2022
Interpretation and application of the DIMF rules
In this session we reviewed topical issues with the carried interest rules, insights on latest commercial trends and the tax issues they prompt.
Thursday, 03 November 2022
Carried interest - achieving commerical aims while maximising tax efficiency
The UK has seen significant and rapid tax policy change in recent years and that is likely to continue in the wake of Covid-19 and wider international tax reform, with an inevitable impact on the PE industry. In this session our tax policy team explained how tax policy is made in the UK, from inception through to announcement and enactment in legislation. Bezhan Salehy, who has recently joined us from HM Treasury, shared his insights into the considerations that drive ministers’ decisions and who and what influences the government’s policy direction.
17 May 2022
Perspectives on tax policy-making
In this session we considered the general earnings charge, ERS rules and how this applies in the context of a fund structure.
Wednesday, 30 November 2022
PE debt restructurings: pre-insolvency tax issues
In this session we reviewed the tax sensitive provisions of allocations and distributions. We also covered relevant investor tax provisions and investment policies.
Thursday, 8 December 2022
Tax provisions in a SPA, SHA and SFA to worry about on a buy out
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In this session we provided an update on the HMRC consulation. The main topics covered were in relation to: shareholder debt, exempt investors, third party debt and the acting together rules.
Wednesday, 06 May 2020
Review of the UK hybrid mismatch consultation
In this session we discussed HMRC's focus on business tax risk and the requirement to notify HMRC of uncertain tax treatment. We looked at the issues PE funds may face and what next for the regime.
Thursday, 14 May 2020
Consultations on disclosing uncertain tax positions and improving tax advisory market standards
In this session we considered the tax sensitive provisions of allocations, distributions, carried interest advance and clawback. We also covered relevant investor tax provisions including investment policy and specific investor type provisions.
Tuesday, 19 May 2020
Understanding the tax provisions in the LPA and a guide to side letter negotiation
In this session we set out some of the key points to be aware of in the use of master holding companies, sharing insight on our experience with Luxembourg and other investment holding vehicles.
Tuesday, 26 May 2020
Tax issues with master holding companies for private equity funds
In this session we considered the ERS rules, carried interest awards and valuation principles in the context of a fund structure, taking account of the specific investor tax provisions and investment management policies.
Employment related securities rules, carried interest awards and valuation principles
In this session we discussed the approach to tax risk management in a changing policy environment by observing the developments in this field since 2010.
Tuesday, 09 June 2020
Developing a tax risk management policy
In this session we offered a deep dive into the DIMF rules, explaining the key terms and how the legislation is intended to operate.
Wednesday, 17 June 2020
DIMF - a technical explanation
In this session we provided an overview of both regimes considered some of the knotty issues with the rules and how they can be addressed.
Wednesday, 24 June 2020
Carry and income based carry
In this session we consider the implications for both UK and non-UK domiciled individuals holding carried interest through a trust.
Thursday, 02 July 2020
The use of trusts to hold fund executives' interests in management groups and funds
In this session we considered the conditions governing the salaried member rules to determine the tax treatment of individual of an LLP, reviewing what characterises a partner.
Wednesday, 08 July 2020
Salaried member rules
In this session we discuss the tax issues in facility agreements including the gross up clause and how it works, issues for non-UK borrowers and lenders, as well as recent trends.
Facility agreements: tax issues and traps for the unwary
In this session we reviewed the latest developments on DAC 6 and set-out the important considerations for managers in the light of the six month reprieve.
Monday, 22 July 2020
DAC 6: managing the countdown to reporting
In this session we considered what we are seeing in the market in terms of lender-led restructures and management driven MIP resets. We also considered the key structure possibilities and outlined the tax treatment.
Thursday, 10 September 2020
Management incentive plans and resets post-Covid with Jamieson Corporate Finance
In this session David Gauke and others provided a review of CGT in light of the OTS consultation with thoughts around potential changes and international comparisons.
Wednesday, 16 September 2020
Potential CGT reform and the impact on the investment management industry
In this session we considered the key issues on a CFOs agenda from an accounting, valuations and regulation perspective including Libor transition, and specific valuation issues arising on including incentive shares, carried interest, portfolio valuation and business combinations
Wednesday, 23 September 2020
Accounting, valuations and related issues facing private fund CFOs.
In this session we covered the key tax issues for credit fund with leveraged sleeves by setting out the typical structures and the issues to consider around which vehicle to use, the capital call facilities, portfolio loans and leveraged co-investment schemes.
Wednesday, 07 October 2020
Tax considerations in fund leverage structures
In this session we covered the interesting points arising from the revised DIMF/carry guidance as well as noting the points omitted from the guidance and our response to the OTS partnership tax review.
DIMF: a technical and practical update
In this session we discussed the background to the IFD and the introduction of the IFPR regime. This included a discussion on the scope of the rules, the material components and the implications for remuneration policy going forward.
Wednesday, 21 October 2020
Impact of the Investment Firms Directive on private fund compensation structures.
In this session we set out the key tax issues arising on lender-led restructurings covering release of debt, debt for equity swaps, and amendments of debt. We also considered sponsor-led restructurings including the injection of additional cash and capitalisation of shareholder debt.
Tuesday, 03 November 2020
Tax issues on restructuring portfolio companies
In this session we considered latest trends in co-investment and the associated tax treatment.
Wednesday, 11 November 2020
Funding co-investment: the tax and commercial pros and cons of various options
In this session we considered latest developments in VAT including the implications on of Brexit on cross-border supplies, the recent VAT grouping consultation, the future of the fund management VAT exemption, the CJEU decision in the BlackRock case, and the uncertain tax treatments consultation.
Wednesday, 18 November 2020
Upcoming and potential VAT changes impacting private fund managers
In this session we considered the latest developments on WHT relief and beneficial ownership following the Danmark cases and other tax policy developments including the OECD Pillar 1 and 2 blueprints, AHC, DAC 6 and changes to the UK hybrid mismatch rules.
Wednesday, 25 November 2020
Recent developments in pan-European deal structuring
In this session we considered key drafting points arising on carried interest partnership agreements with consideration of the relevant tax issues.
Key drafting points in carried interest partnership agreements
Wednesday, 02 December 2020
Thursday, 15 October 2020
Tuesday, 14 July 2020
In this session we talked through some of the key issues being investigated but HMRC and their approach to enquiries.
Tuesday,10 March 2020
Litigation with HMRC: tips and war stories
In this session we discussed the impact of Covid-19 on UK corporate residence rules and the tax implications that may apply.
Thursday, 9 April 2020
Update on Covid-19 measures from tax perspective for houses and investees
In this session we considered the history of closed ended credit fund structures, how they have developed materially over the past 10 years and the main closed ended strategies employed.
Thursday, 16 April 2020
Credit fund structuring - what you need to know
In this session we focused on the key differences between the UK and Luxembourg regimes to identify the key requirements for a competitive regime in a PE context.
Wednesday, 22 April 2020
Discussion on the UK Asset Holding Company consultation for private equity companies.
In this session we explored topical VAT isues including: Covid-19 VAT measures, partial exemption special methods, Melford Capital tribunal decision, deal fees and reverse charge.
Tuesday, 28 April 2020
VAT treatment for funds and managers in the UK, Luxembourg and the Islands
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Wednesday, 03 June 2020
In this session we focused on the key differences between the UK and Luxembourg regimes to identify the key requirements for a competitive regime in a credit fund context.
Thursday, 30 April 2020
Discussion on the UK Asset Holding Company consultation for credit fund holding and finance companies.
In this session we provided an overview of the anti-hybrid mismatch rules. With a particular focus on: - Interaction with other interest restriction rules - Application to third party lenders - Imported mismatches following introduction of the Lux hybrid rules
Tuesday, 11 February 2020
Anti-hybrid mismatch rules in the UK and Luxembourg
Become a PETF member to attend.
In this session we provided an overview of what we are seeing in practice in relation continuation funds, with a focus on the types of transaction and structures and the tax issues that arise with asset and fund level transactions, along with tax issues for carry holders.
Wednesday, 12 October 2022
In this session we provided a recap on the salaried member rules, setting out the background, the ways in which the conditions operate and what the next steps are following the Bluecrest decision.
Thursday, 20 October 2022
Salaried member rules in light of the Bluecrest decision
Previous event resources
Upcoming events
Following developments in carried interest regimes around the world, in this session we will explore the key aspects of regimes in a number of jurisdictions to see how they compare.
Overseas carried interest regimes – a comparison
Wednesday, 18 January 2023, 10:30 - 11:30
In this session we will review the tax sensitive provisions of allocations and distributions. We will also cover relevant investor tax provisions and investment policies.
Thursday, 8 December 2022, - 10:30 - 11:30
Access event details
Despite the anti-hybrid and interest restriction rules being in place for over 5 years in the UK and a number of years in Luxembourg, there is still much to learn about the ins and outs of the regimes and their impact in practice. In this session we will share the common issues and key learnings.
Anti-hybrid and interest barrier rules in UK and Lux – a reminder of their impact in practice
Tuesday, 7 February 2023, 10:30 - 11:30
Cross-border and remote working has increased in popularity since the pandemic. In this session we will provide an update on the key tax considerations and traps for the unwary with a more mobile workforce.
Mobility update including pre-arrival/departure planning
Tuesday 9 May 2023, 10:30 - 11:30
As the EU remains active on tax policy, in this session we will provide an update on the latest tax files with expert insight from Brussels to understand which initiatives stand a chance of progressing and which will languish.
Update on EU tax developments with Danny O’Connell (Head of Brussels Office, AIMA)
Tuesday, 28 February 2023, 10:30 - 11:30
In this session we will explore latest trends in co-investment and the tax and commercial pros and cons of various funding options. We will also cover the often neglected UK tax reporting aspects you will need to consider under the various options
Co-invest structuring, co-invest funding and UK tax reporting
Thursday 27 April 2023, 10:30 - 11:30
20 May 2021
27 May 2021
On 21 December 2021 the European Commission published a draft Directive designed to target EU based shell entities that do not meet a minimum substance threshold. This reflects a renewed interest in tackling the use of such entities and was widely feared as a tightening of the screw on the use of holding companies in the EU. This session highlighted the key requirements and how to navigate the potential consequences as a result of these changes.
Thursday, 20 January 2022
The new anti-avoidance directive - EU measures on holding/shell companies
As the UK AHC regime legislation nears enactment and with HMRC guidance on the horizon, we discussed the key aspects you will need to consider to successfully implement a UK AHC within your structure. We also shared our experiences from early-adopters to help you avoid traps for the unwary.
Thursday, 03 February 2022
Successful implementation of a UK AHC and traps for the unwary
Thursday, 10 February 2022
Thursday, 24 February 2022
In this session we shared the highlights from the second edition of our global tax policy monitor to keep you abreast of critical international tax developments from the EU, OECD and a number of other jurisdictions.
Thursday, 31 March 2022
In this session our tax policy team explained how tax policy is made in the UK, from inception through to announcement and enactment in legislation. Bezhan Salehy, who has recently joined us from HM Treasury, shared his insights into the policy making process.
Tuesday, 17 May 2022
Over the last few years there has been significant growth in M&A involving fund managers. This session walked through the seller considerations on a typical acquisition of a partnership interest in a House LLP including the underlying assets of shares, goodwill, carried interest,and co-invesment. We also covered the buyer considerations around historic risks and post-completion tax considerations.
Thursday, 26 May 2022
Investment and Asset Management M&A - key tax considerations for buyers and sellers
Tax and valuation considerations are important factors with resetting MIPs and late carry awards. In the session we explained the tax implications on those awards and discussed the critical valuation issues that need to be considered including the importance of a valuation and the different approaches that can be taken.
Tuesday, 21 June 2022
Tax and valuation considerations with resetting MIPs and late carry awards
20 January 2022
03 February 2022
Thursday, 10 March 2022
Tuesday, 22 March 2022
In this session we will consider the general earnings charge, ERS rules and how this applies in the context of a fund structure.
Wednesday, 30 November 2022, 10:30 - 11:30
Tax developments impacting investment fund managers
member-only events
As the QAHC regime’s first birthday draws near we will share our experiences from early-adopters and help you avoid traps for the unwary. This session will also coincide with the UK Spring Budget so we will report on interesting developments for the industry.
QAHC – reflections a year into the regime and budget update
Wednesday, 16 March 2023, 10:30 - 11:30
In this session we covered the range of tax issues arising from flexible working practices across borders including employment tax, corporation tax and VAT considerations.
Wednesday, 16 November 2022
Tax considerations for mobile executives
| Damien Crossley & Ceinwen Rees
| James McCredie & Philip Swinburn
| Mark Baldwin & Bezhan Salehy
| James McCredie, Joe Robinson & Janice Luo
| Jeremy Moncrieff & Beth Leggate
| Sophie Donnithorne-Tait & Shaul Steinberg
| James McCredie & Janice Luo
| Jeremy Moncrieff & Alex Ereira
| Rhiannon Kinghall Were & Bezhan Salehy
| Rhiannon Kinghall Were & Ceinwen Rees
| Mark Baldwin & Joe Robinson
| Ceinwen Rees, Jeremy McCallum, Trang Nguyen & Rachel Chun
| Chris Mortimer, Charishma Bhujohory & Jack Slater
| Damien Crossley & Mark Baldwin
| James McCredie & Alicia Thomas
| Ceinwen Rees
| Shailen Patel, Siobhan Holroyd & Janice Luo
| Damien Crossley, Mark Baldwin & Rhiannon Kinghall Were
| Bahar Eken
| James McCredie & Ceinwen Rees
| Alicia Thomas & Philip Swinburn
| Damien Crossley & Rhiannon Kinghall Were
| James McCredie & Rhiannon Kinghall Were
| Damien Crossley, Rob Collard & Janice Luo
| Lora Froud & Alicia Thomas
| Gregory Price, Mark Baldwin, Rhiannon Kinghall Were & Jack Slater
| Rhiannon Kinghall Were
| James McCredie, Shailen Patel and Lucy Urwin
| Rob Collard, Alex Ereira & Janice Luo
| Mark Baldwin & Alicia Thomas
| Chris Acton, Alicia Thomas & Gary Stokes
| Rhiannon Kinghall Were & Chris Mortimer
| Chris Mortimer & Charishma Bhujohory
| Alicia Thomas & Ceinwen Rees
| Peter Abbott & Shaul Steinberg
| Shailen Patel & Ras Berglund
| Mark Baldwin & Damien Crossley
| Damien Crossley & James McCredie
| Shailen Patel & Janice Luo
| Damien Crossley, David Gauke & Rhiannon Kinghall Were
| Ceinwen Rees, Jeremy McCallum, Rhiannon Kinghall Were, Dan Okougha & Arfan Iqbal
| Kirsten Prichard Jones, Shaul Steinberg & Alex Ereria
| Mark Baldwin & James McCredie
| Jennifer Smithson & Ceinwen Rees
| Damien Crossley & Alicia Thomas
| Jeremy McCallum, Ceinwen Rees & Rhiannon Kinghall Were
| James McCredie
| Mark Baldwin & Gregory Price
| Damien Crossley, Ceinwen Rees & Rhiannon Kinghall Were
| Chris Mortimer
| Ashley Greenbank, Gregory Price & Rhiannon Kinghall Were
| Gideon Sanitt, James McCredie & Jackelyn West
In this session we considered topical credit fund structuring issues including the introduction of the QAHC regime, managing tax issues in respect of US investments, navigating European loan origination and ATAD 1 & 2, alongside areas of investor focus such as maintaining transparency, tax risk management policies/codes of conduct and ATAD 1/CFC concerns.
| Ceinwen Rees & Alex Ereira
Wednesday, 21 September 2022
Credit fund structuring and areas of investor focus
In this session we reflected on the the qualifying asset holding company (QAHC) regime in its first six months of operation. We were joined by HMRC’s QAHC lead Adeline Chan and Natalie Bird from HM Treasury to hear first hand how the QAHC regime has developed, including HMRC’s approach to QAHCs in practice, and insights into the remaining challenges with a particular focus on the ownership condition and the ongoing work being done in this regard.
| Adeline Chan (HMRC), Natalie Bird (HMT), Damien Crossley & Rhiannon Kinghall Were
Tuesday, 27 September 2022
QAHC regime
Incentivising management teams in uncertain times may call for a MIP reset if strategies and goals have changed or if the management equity is significantly underwater. In this session we will explore how to go about this and the valuation considerations needed.
MIP resets including valuation considerations
Wednesday, 29 March 2023, 10:30 - 11:30
As the QAHC regime’s first birthday draws near we will share our experiences from early-adopters and help you avoid traps for the unwary. This session will also coincide with the UK Spring Budget where we will report on interesting developments for the industry.
Thursday, 16 March 2023, 10:30 - 11:30
In this session, on 28 February 2023, Danny O’Connor (Head of Brussels Office, AIMA), James McCredie and Rhiannon Kinghall Were gave a presentation on the latest EU tax developments including a discussion on the latest revisions to ATAD 3 / Unshell Directive and their implications for asset managers.
| Danny O'Connell (AIMA), James McCredie, Rhiannon Kinghall Were
Tuesday, 28 February 2023
In this session, on 7 February 2023, Damien Crossley, Alex Ereira and Joe Robinson gave a presentation on the application of the corporate interest restriction and anti-hybrid rules in relation to UK and Luxembourg AHCs. An overview of the rules in each jurisdiction was provided along with some real life examples and suggestions on how to manage the points of complexity and uncertainty that the rules create.
| Damien Crossley, Alex Ereira and Joe Robinson
Tuesday, 7 February 2023
Application of corporate interest restriction and anti-hybrid rules to UK and Luxembourg AHCs
In this session, on 18 January 2023, Ceinwen Rees, Bezhan Salehy and George Apps gave a presentation on carried interest taxation: the international landscape. As part of this session, they explored the varying requirements and tax rates in a number of jurisdictions, practical points to consider, and possible future direction within the policy landscape. The slides from the session are now available.
| Bezhan Salehy, Ceinwen Rees and George Apps
Wednesday, 18 January 2023
Overseas carried interest regimes - a comparison
In the session hosted on 9 May 2023, Philip Swinburn and Richard Giangrande gave a presentation on pre-arrival and post-departure planning. The session covered the tax considerations for ad-hoc working arrangements and pre-departure planning for both inbound and outbound individuals.
| Philip Swinburn and Richard Giangrande
Tuesday 9 May 2023
2023
In this session Rhiannon Kinghall Were and Mark Baldwin were joined by members of HMRC’s Financial Services Tax Policy and Technical Team to discuss recent developments, trends and policy issues affecting the industry. No slides were prepared.
| Rhiannon Kinghall Were and Mark Baldwin
Tuesday, 16 May 2023
HMRC update
View previous events
In this session we explored the types of situations which may warrant tax insurance to be taken, what tax risks should or shouldn’t be insured, and the steps involved in the process. The session covered W&I and specific tax insurance, as well as discussing how the tax insurance market has developed, practical points to be aware of, and key policy terms.
| Sophie Donnithorne-Tait, Jeremy Moncrieff and Beth Leggate
Wednesday, 24 May 2023
What tax risks can and should be insured?
Chris Mortimer, Jack Slater and Lucy Green provided an update on VAT as it impacts managers, funds, AHCs and deals. They discussed VAT and asset holding companies, deal fee structuring and the consultation on the VAT treatment of fund management.
| Chris Mortimer, Jack Slater and Lucy Green
Tuesday 6 June 2023
Update on VAT as it impacts managers, funds, AHCs and deals
In this session we covered the tax and design considerations of the carried interest award process to help you streamline the process.
| Damien Crossley, Joe Maughan and Klaudija Brami
Wednesday, 21 June 2023
Streamlining your carried interest award process
In this session we explored the latest trends in co-investment and the tax and commercial pros and cons of various funding options. We also covered the often neglected tax reporting aspects you need to consider under the various options.
| Ceinwen Rees and James McCredie
Thursday 27 April 2023
As the QAHC regime's first birthday draws near we will share our experiences from early adopters and help you avoid traps for the unwary. This session explored with the UK Spring Budget where we will report on interesting devlopments for the industry.
| Sophie Donnithorne-Tait, Rhiannon Kingwall Were and Bezhan Salehy
Thrusday, 16 March 2023
QAHC - reflections a year into the regime and budget update
In this session, on 29 March 2023, Alex Edmondson, Shaul Steinberg and Janice Luo gave a presentation on MIP resets and valuation considerations. The session explored the commercial context of MIP resets, including the rationale and practicalities, as well as explaining how to determine the market value of the MIP shares.
| Alex Edmondson, Shaul Steinberg and Janice Luo
Wednesday, 29 March 2023
We will be in touch in the new year with details of our events for 2024.
Our events programme has finished for 2023.
This session will explore the taxation of carried interest for PE executives moving to and from the UK taking account of the different treatment of carried interest in different jurisdictions and EU social security rules.
Taxation of carried interest for mobile executives
Wednesday 21 February 2024, 10:30 - 11:30
Following the BlueCrest Court of Appeal decision we will review the risk of miscellaneous income tax charge in a private capital setting together with an update on the salaried member rules in light of a more aggressive approach from HMRC.
LLP update following BlueCrest Miscellaneous Income CoA decision and recent HMRC SMR “hardening”
Tuesday 30 January 2024, 10:30 - 11:30
This session, delivered by Ceinwen Rees on 13 September 2023, provided an overview of the key tax considerations from an investor perspective when undertaking a fund review.
Wednesday 13 September 2023
Reviewing a fund from an investor perspective
Transactions
Employment and mobility tax
Disputes and tax risk management
Other
Operational tax – managing compliance and reporting risk over the lifecycle of a fund
In this session we focused on continuation funds transactions.
Tuesday, 9 May 2023
Discussion on the UK Asset Holding Company consultation for private equity companies
Discussion on the UK Asset Holding Company consultation for credit fund holding and finance companies
Update of Asset Holding Company Consultation
Tuesday, 6 June 2023
Wednesday, 13 September 2023
Damien Crossley and Joe Robinson provided an overview of the key considerations with NAV based financings, exploring the types of structures we are seeing in practice and the tax considerations that can arise.
| Damien Crossley and Joe Robinson
Wednesday, 27 September 2023
Key considerations with NAV based financings
Following the political party confernce season, we explored potential UK tax reform affecting private capital managers ahead of the next general election.
| Damien Crossley, Rhiannon Kinghall Were and Bezhan Salehy
Thursday 12 October 2023
Potential UK tax reform affecting private capital managers
Thursday, 12 October 2023
In this session we discussed how to handle HMRC enquiries as well as how the courts approach tax cases.
| Gideon Sanitt, Ashley Greenbank and Sarah Ling
Tuesday 17 October 2023
Handling HMRC enquiries and approach of courts in tax cases
Tuesday, 17 October 2023
In this session we provided an overview of the tax issues that can arise in secondaries.
| James McCredie and George Apps
Tuesday 7 November 2023
Tax issues in secondaries – issues to be aware of as a manager
In this session James McCredie, Rasmus Berglund and Philip Swinburn explained the growing interest in shadow carry plans and highlighted traps for the unwary.
| James McCredie, Rasmus Berglund and Philip Swinburn
Wednesday 22 November 2023
Global shadow carry plans
Wednesday, 22 November 2023
In this event, we explored the wide range of debt and equity instruments that can be used to fund an asset holding company in Luxembourg and in the UK.
| Sophie Donnithorne-Tait and Charishma Bhujohory
Wednesday 6 December 2023
Financing your QAHC and Luxembourg asset holdco
Wednesday, 6 December 2023
Ahead of the general election we will set out how to prepare for potential changes to investment management taxation including non-doms and carried interest.
Understanding proposed non-dom tax changes and an update on potential carried interest tax reform
Tuesday 30 April 2024, 10:30 - 11:30
In this session we will explore the key areas where VAT might create unnecessary leakage.
Avoiding unnecessary VAT leakage in a private capital setting
Tuesday 9 April 2024, 10:30 - 11:30
Managing risk remains a critical part of the tax function. In this session we will examine the latest on CCO and the new tax fraud offence, tax risk more broadly and how to avoid and, failing that, close down HMRC enquiries.
CCO, taxpayer behaviour and other tax risks: dealing with HMRC as a regulator
Wednesday 20 March 2024, 10:30 - 11:30
In this session we will review the different ways of using carried interest as a reward and retention tool.
Slicing up the cake – different ways of using carried interest as a reward and retention tool
Thursday 13 June 2024, 10:30 - 11:30
With the QAHC regime established for over two years we will explore the technical issues and practical challenges we see in practice.
Tax issues facing credit funds in terms of fund structuring, asset holdcos and deployment
Wednesday 22 May 2024, 10:30 - 11:30
In this session we will share our thoughts on the Supreme Court decision in the Vermilion case on the meaning of the deeming rule in the employment relation securities (ERS) rules and what this means in practice for private capital managers.
| Damien Crossley, Mark Baldwin and Florence Barnes
Thursday 18 January 2024
What is an ERS following the Vermilion Supreme Court decision and what protective steps should managers be taking
2024
In this session, Alex Ereira, Joe Robinson and Bezhan Salehy provided an update on LLPs following the Court of Appeal decision in BlueCrest, with a focus on Miscellaneous Income and the recent "hardening" of the Salaried Member Rules.
| Bezhan Salehy, Joe Robinson, Alex Ereira
Tuesday 30 January 2024
In this session, Philip Swinburn and George Apps explored the taxation of carried interest for PE executives moving to and from the UK, including the treatment of carried interest in different jurisdictions and EU social security rules.
| George Apps and Philip Swinburn
Wednesday 21 February 2024
In this session Gideon Sanitt, Jeremy McCallum, Sarah Ling and Victoria Braid discussed managing risk as a critical part of the tax function. They examined the latest on CCO and the new tax fraud offence, tax risk more broadly and how to deal with HMRC enquiries.
| Gideon Sanitt, Jeremy McCallum, Sarah Ling and Victoria Braid
Wednesday 20 March 2024
In this session Chris Mortimer and Lucy Green explored the key areas where VAT might create unnecessary leakage.
| Chris Mortimer and Lucy Green
Tuesday 9 April 2024
In this session, James McCredie, Jennifer Smithson and Alex Jones discussed the proposed changes to the non-dom regime and provided an update on potential carried interest reform.
| Alex Jones, James McCredie and Jennifer Smithson
Tuesday 30 April 2024
In this session, Sophie Donnithorne-Tait and Eugene Atkinson discussed the tax issues facing credit funds, focussing on fund structuring, asset holdcos and deployment.
| Sophie Donnithorne-Tait and Eugene Atkinson
Wednesday 22 May 2024
In this session Damien Crossley and George Apps reviewed the different ways of using carried interest as a reward and retention tool.
| Damien Crossley and George Apps
Thursday 13 June 2024
We will be in touch in due course with details of our Autumn events programme.
Event description coming soon....
Understanding the new carried interest regime - the decided changes and the open issues including how a holding period requirement might operate
Event details coming soon
Wednesay 13 November, 10.30-11.30am
Update on Pillar Two and its application in a private capital setting
Thursday 10 October, 10.30-11.30am
The UK statutory resident tax recap
Thursday 3 October, 10.30-11.30am
In this session, Jenny Smithson and Joe Robinson discussed the UK statutory residence test, providing an overview of the rules, and outlining ‘split year’ treatment, common pitfalls, practicalities relating to residence, and highlighting group related tax issues.
| Jennifer Smithson and Joe Robinson
Wednesday 3 October 2024
UK statutory residence test recap
In this session, Greg Price, Eugene Atkinson and Bezhan Salehy explained the relevance and application of Pillar Two for private capital, providing an outline of the issues being seen at both the house and fund levels.
| Greg Price, Eugene Atkinson and Bezhan Salehy
Thursday 10 October 2024
Pillar Two for private capital
New carried interest regime - impact on credit funds and required IBCI changes to allow credit funds to qualify for the new regime
Wednesay 27 November, 10.30-11.30am
New carried interest regime - impact of its extraterritorial scope
Wednesay 4 December, 10.30-11.30am
In this session on Wednesday 13 November, James McCredie and George Apps discussed the new carried interest regime covering the decided changes and the open issues including how a holding period requirement might operate.
Wednesday 13 November 2024
Autumn Budget - understanding the new carried interest regime
- roundtable discussions on key developments; - technical training sessions; - guest speakers; and - social events.
Additional key cases
SP D12
HMRC statements of practice
2003 MoU - carry
2003 MoU - management equity
1987 BVCA/HMRC statement
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BVCA/HMRC MoUs
Guidance
Legislation
Mixed member rules
UK AHC
Regulations
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Offshore fund rules
Bluecrest – First-tier Tribunal
Carried interest rules
IBCI rules
DIMF rules
SP 1/01
Blackrock Holdco LLC5 – Upper Tribunal
Euromoney plc – Upper Tribunal
Vermillion Holdings Limited – Upper Tribunal
Click on the links below to reach the most frequently referred to legislation and guidance relevant to private fund managers.
Wednesday, 16 November 2022, 10:30 - 11:30
Ranked 1st for Tax
The Times Best Law Firms 2019, 2020, 2021 and 2022
Forming part of a wider Macfarlanes tax offering we offer a broad range of tax services including: transaction structuring, fund formation, group tax advice, dispute resolution, operational tax and tax risk management. We have dedicated specialists in areas such as VAT, transfer pricing, valuation, employee incentives and mobility, corporate advisory and tax policy.
Our tax and reward team is consistently recognised as one of the leading tax advisory practices in the UK.
EFAMA European Fund and Asset Management Association
Invest Europe The representative body for Europe’s private equity, venture capital and infrastructure industry
The Law Society The independent professional body for solicitors
ProShare The voice of employee share ownership
EuRA The European Relocation Association
CIOT Chartered Institute of Taxation
IBA International Bar Association
ICAEW Institute of Chartered Accountants in England and Wales
BWAM Black Women in Asset Management
WIT Women in Tax
SPL Share Plan Lawyers
WIN Women of IFA Network
IFA International Fiscal Association
IA The Investment Association
BVCA British Private Equity and Venture Capital Association
AIMA Alternative Investment Management Association
ACC Alternative Credit Council
Partner DD +44 020 7849 2728 damien.crossley@macfarlanes.com
Damien Crossley
Industry bodies and professional memberships
Senior Advisor DD +44 020 7849 2603 mark.baldwin@macfarlanes.com
Mark Baldwin
Partner DD +44 020 7849 2751 ceinwen.rees@macfarlanes.com
Ceinwen Rees
Partner DD +44 020 7849 2129 james.mccredie@macfarlanes.com
James McCredie
Partner DD +44 020 7849 2773 alicia.thomas@macfarlanes.com
Alicia Thomas
Senior Counsel DD +44 020 7849 2149 chris.mortimer@macfarlanes.com
Chris Mortimer
Partner DD +44 020 7791 2670 sophie.donnithorne-tait@macfarlanes.com
Sophie Donnithorne-Tait
Partner DD +44 020 7849 4211 joe.robinson@macfarlanes.com
Joe Robinson
Partner DD +44 020 7849 2476 jeremy.moncrieff@macfarlanes.com
Jeremy Moncrieff
Tax policy specialist DD +44 020 7849 2290 bezhan.salehy@macfarlanes.com
Bezhan Salehy
Head of tax policy DD +44 020 7791 4131 rhiannon.kinghallwere@macfarlanes.com
Rhiannon Kinghall Were
Top ranked for tax
The Times Best Law Firms 2020-2024
Legal 500 2023
Tier 1 for Corporate tax
The Drawdown Awards 2020-2022
Winner of the advisory/consultancy tax category
The Times Best Law Firms 2019-2023
Ranked first for tax
Head of VAT DD +44 020 7849 2149 chris.mortimer@macfarlanes.com
Partner DD +44 020 7849 2603 mark.baldwin@macfarlanes.com
Senior Associate DD +44 020 7849 4211 joe.robinson@macfarlanes.com
Previous events
2020 events
2021 events
2022 events
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In this session we will cover the range of tax issues arising from flexible working practices across borders including employment tax, corporation tax and VAT considerations.
We will consider the particular issues with the carried interest rules and how they can be addressed.
03 November 2022, 10:30 - 11:30
2023 events
Back to upcoming events
James McCredie & Alicia Thomas
Damien Crossley & Mark Baldwin
Rhiannon Kinghall Were & Bezhan Salehy
6
Chris Mortimer, Charishma Bhujohory & Jack Slater
Ceinwen Rees, Jeremy McCallum, Trang Nguyen & Rachel Chun
Mark Baldwin & Joe Robinson
Rhiannon Kinghall Were & Ceinwen Rees
Jeremy Moncrieff & Alex Ereira
James McCredie & Janice Luo
Ceinwen Rees & Alex Ereira
Adeline Chan (HMRC), Natalie Bird (HMT), Damien Crossley & Rhiannon Kinghall Were
Ashley Greenbank, Gregory Price & Rhiannon Kinghall Were
Ceinwen Rees, Jeremy McCallum, Rhiannon Kinghall Were, Dan Okougha & Arfan Iqbal
DAC 6: managing the countdown to reporting.
In this session we considered the key issues on a CFOs agenda from an accounting, valuations and regulation perspective including Libor transition, and specific valuation issues arising on including incentive shares, carried interest, portfolio valuation and business combinations.
Shailen Patel & Janice Luo
Rhiannon Kinghall Were & Chris Mortimer
Rob Collard, Alex Ereira & Janice Luo
Lora Froud & Alicia Thomas
Damien Crossley, Rob Collard & Janice Luo
Shailen Patel, Siobhan Holroyd & Janice Luo
In this session we explored the types of situations which may warrant tax insurance to be taken, what tax risks should or shouldn’t be insured, and the steps involved in the process.
Sophie Donnithorne-Tait, Jeremy Moncrieff and Beth Leggate
Wednesday 24 May 2023
Damien Crossley & Ceinwen Rees
Damien Crossley & James McCredie
James McCredie & Rhiannon Kinghall Were
Danny O'Connell (AIMA), James McCredie and Rhiannon Kinghall Were
Gideon Sanitt, James McCredie & Jackelyn West
Litigation with HMRC: tips and war storiesVAT treatment for funds and managers in the UK, Luxembourg and the Islands
Mark Baldwin & Gregory Price
Jeremy McCallum, Ceinwen Rees & Rhiannon Kinghall Were
Developing a Tax Risk Management policy
James McCredie, Shailen Patel and Lucy Urwin
Gregory Price, Mark Baldwin, Rhiannon Kinghall Were & Jack Slater
Bahar Eken
Chris Mortimer & Charishma Bhujohory
In this session Chris Mortimer, Jack Slater and Lucy Green provided an update on VAT as it impacts managers, funds, AHCs and deals. They discussed VAT and asset holding companies, deal fee structuring and the consultation on the VAT treatment of fund management.
Chris Mortimer, Jack Slater and Lucy Green
Damien Crossley, Ceinwen Rees & Rhiannon Kinghall Were
Chris Acton, Alicia Thomas & Gary Stokes
Damien Crossley & Rhiannon Kinghall Were
Damien Crossley, Mark Baldwin & Rhiannon Kinghall Were
Damien Crossley, Alex Ereira and Joe Robinson
Sophie Donnithorne-Tait, Rhiannon Kinghall Were and Bezhan Salehy
Thursday, 16 March 2023
James McCredie & Philip Swinburn
Alicia Thomas & Philip Swinburn
Philip Swinburn and Richard Giangrande
Peter Abbott & Shaul Steinberg
Sophie Donnithorne-Tait & Shaul Steinberg
Alex Edmondson, Shaul Steinberg and Janice Luo
Kirsten Prichard Jones, Shaul Steinberg & Alex Ereria
James McCredie & Ceinwen Rees
James McCredie, Joe Robinson & Janice Luo
Jeremy Moncrieff & Beth Leggate
Damien Crossley & Alicia Thomas
Jennifer Smithson & Ceinwen Rees
Mark Baldwin & James McCredie
Mark Baldwin & Damien Crossley
Shailen Patel & Ras Berglund
Impact of the Investment Firms Directive on private fund compensation structures
Alicia Thomas & Ceinwen Rees
Thursday, 9 December 2021
Bezhan Salehy, Ceinwen Rees and George Apps
Ceinwen Rees and James McCredie
In this session we covered an update on tax and design considerations of the carried interest award process to help streamline the process.
Damien Crossley, Joe Maughan and Klaudija Brami
9
8
7
Damien Crossley, David Gauke & Rhiannon Kinghall Were
2020 Events
Mark Baldwin & Alicia Thomas
2021 Events
Mark Baldwin & Bezhan Salehy
2022 Events
Back to events
Rhiannon Kinghall Were and Mark Baldwin
Tuesday 16 May 2023
Damien Crossley and Joe Robinson
Wednesday 27 September 2023
Key considerations with NAV based findings
2023 Events
Damien Crossley, Rhiannon Kinghall Were and Bezhan Salehy
Rhiannon Kinghall Ware and Bezhan Salehy
Gideon Sanitt, Ashley Greenbank and Sarah Ling
James McCredie and George Apps
Tax issues in secondaries
James McCredie, Rasmus Berglund and Philip Swinburn
Sophie Donnithorne-Tait and Charishma Bhujohory
Damien Crossley, Mark Baldwin and Florence Barnes
2024 events
2024 Events
Bezhan Salehy, Joe Robinson, Alex Ereira
George Apps and Philip Swinburn
Gideon Sanitt, Jeremy McCallum, Sarah Ling and Victoria Braid
Chris Mortimer and Lucy Green
Damien Crossley and George Apps
In this session, Jenny Smithson and Joe Robinson discussed the UK statutory residence test.
Jennifer Smithson and Joe Robinson
Thursday 3 October 2024
Greg Price, Eugene Atkinson and Bezhan Salehy
Autumn Budget – understanding the new carried interest regime
Explainers
At Autumn Budget 2021 the government launched....
By Bezhan Salehy 09 May 2022
UK government publishes summary of responses to corporate re-domiciliation consultation
In a speech at Innovate Finance Global Summit on Monday 4 April, Johne Glen, Economic Secretary to the Treasury, set out the UK government's goal to become a...
By Rebecca Rose on 08 Apr 2022 15:32 in Tax News
Crypto: update to Investment Manager Exemption
By Rhiannon Kinghall Were on 08 Apr 2022 16:16 in PETF blog...
By Rhiannon Kinghall Were 08 Apr 2022 16:16 in PETF blog
Our session on 31st March provided an overview of the latest global tax policy developments with a spotlight on a few territories where there have been notable....
By Natasha Behan on 05 Jul 2021 18:04 in Articles and mailing
Case law insights
We often advise funds on the employment tax implications when granting carried interest and on events such as when fund executives sell their carry. This ....
By Janice Luo 29 Apr 2022
Carried interest considerations
On 6 May the OECD published its proposal for the exclusion of regulated financial services activities from Pillar One of the BEPS 2.0 project...
Pillar One: assessing the asset management carve-out
UK portfolios under a master holding company
Read More
Vitae periores et quaerat proident praesent exceptur.
