UK corporate offence of failure to prevent tax evasion
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
On 28 April 2025, the UK government published draft legislative amendments to: - Align the UK’s domestic tax rules on permanent establishments (PE) with the 2017 Organisation for Economic Co-operation and Development (OECD)...more
Welcome to April’s edition of our UK Tax Round Up. While this month has been quiet on the case law front, there have been a number of HMRC announcements and updates to prior published guidance along with published responses...more
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
Underneath the headline points, the Budget contained a number of measures designed to fulfil the Chancellor’s objective of encouraging growth and investment. There was broadly good news for those investing in UK real estate....more
Amongst the usual round of rate changes and technical measures (including replacement of the capital allowances “super-deduction” regime with full expensing for companies incurring expenditure on plant and machinery over the...more
Welcome to July’s edition of the UK Tax Round Up. This month has seen an interesting decision of the First-tier Tribunal on the salaried member rules as they apply to asset manager LLPs, a surprising decision on the terms...more
The new regime for asset holding companies (the qualifying asset holding company (QAHC) regime) was published last month as part of the draft Finance Bill 2021-22. In essence, the term 'asset holding companies' refers to...more
As part of an initiative to promote UK funds the government is consulting on changes to the UK REIT regime. These changes are intended to make the UK REIT regime more attractive and simpler....more
The Chancellor of the Exchequer delivered the United Kingdom (“UK”) Budget for 2020 on 11 March 2020. The Budget was delivered against a backdrop that very few people could have anticipated at the commencement of the year....more
In the recent case of Melford Capital General Partner Ltd v HMRC, the FTT concluded that a UK GP was entitled to full recovery of input VAT incurred on the establishment and operational costs of a UK LP Fund of which it was...more
UK General Tax Developments - Date set for next UK Budget - The first Budget of the new Conservative government will be held on Wednesday 11 March. There has been significant speculation that there will be a major...more
In the Finance Act 2018, the UK Government enacted a number of changes to the information required in partnership returns that raised the concern of undue and impracticable administrative burden being imposed on UK investment...more
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
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
After numerous UK tax changes affecting asset managers over the past few years – not least the wholesale re-vamping of the tax treatment of carried interest and other fund participations for investment fund managers – the UK...more
HMRC published a discussion paper on 8 August 2016 setting out how the UK’s plant and machinery lease taxation rules might be changed in light of IFRS 16, the new accounting standard for leases. Responses to the paper...more
In its July 1, 2015 decision in the case of Anson v. HM Revenue & Customs (2015 UKSC 44), the Supreme Court of England and Wales ruled that a Delaware limited liability company was “transparent” for UK income tax purposes. A...more