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UK Government Carried Interest Tax Reforms Consultation Process: No New Conditions, Territorial Limits Clarified

June 2025 – The UK Government has published its response to the consultation on its proposal to change the tax treatment of carried interest, confirming the expected final shape of the new regime which will take effect from...more

BlueCrest FTT Decision –  Salaried Member Rules and Asset Managers

The recent decision of the First-tier Tribunal (FTT) in BlueCrest Capital Management (UK) LLP v HMRC (29 June 2022) is the first time the UK’s salaried member rules (the Rules) have been considered in the context of an asset...more

HMRC Clarifies Application of QAHC Regime to Corporate Lending Vehicles

HMRC has recently updated the guidance relating to the UK’s new qualifying asset holding company (QAHC) tax regime which was introduced from 1 April 2022. The new guidance clarifies HMRC’s approach to whether corporate...more

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