Navigating Russia Sanctions
Private Equity and Delaware Law – Part One
U.S. venture capitalists investing at the early stages (Seed and Series A) in a UK (or other non-U.S.) company often require that the company “flips” its corporate structure and establishes a U.S. (most commonly Delaware)...more
In Syspal Capital Limited v. Truman & Anor [2024] EWHC 1561 (ChD), the court had to determine the correct interpretation of a particular clause in a company’s articles of association (articles) that concerned deemed transfer...more
UK regulators have recently announced a number of reforms for banks and other financial institutions. - On 23 November 2023, the Prudential Regulation Authority (PRA) and the Financial Conduct Authority (FCA) (together,...more
There has been increased focus recently among London-listed companies in exploring US listings, whether as a further listing or migrating from London altogether. This is primarily being driven by companies seeking to close...more
As part of the Spring 2023 Budget, Chancellor Jeremy Hunt has scrapped plans to require sovereign wealth funds to pay corporation tax on property and commercial enterprises. The United Kingdom (“UK”) government had...more
The Chancellor of the Exchequer delivered the United Kingdom (“UK”) Budget for 2023 on 15 March 2023. The Budget was delivered against a backdrop of some familiar political headwinds, caused by the lengthy shockwaves of...more
HMRC has recently updated its guidance on the UK’s new qualifying asset holding company (QAHC) tax regime, which was introduced from 1 April 2022, to include examples of the application of the QAHC regime “activity condition”...more
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
The UK qualifying asset holding company (“QAHC”) tax regime came into force on 1 April 2022. The regime provides a generous relaxation of certain UK tax rules for UK resident investment vehicles meeting certain eligibility...more
Introduction The UK’s new Qualifying Asset Holding Company Regime (the “QAHC Regime”) comes into effect on 1 April 2022. The main objective of the regime is to make the UK a more desirable jurisdiction from which funds (which...more
The United Kingdom ("UK") Qualifying Asset Holding Company ("QAHC") regime (at Schedule 2 to Finance Act 2022) comes into force on 1 April 2022. The HM Revenue & Customs ("HMRC") policy paper dated 27 October 2021 states:...more
On 10 February 2022 HM Treasury published a response document (Response) to its January 2021 ‘call for input’ on a review of the UK funds regime. The review was necessarily wide-ranging, covering direct and indirect tax,...more
Look out, Luxembourg – the UK is on the verge of a set of preferential tax treatments sure to attract asset holding companies. Our Finance Group highlights what it means for the UK investment funds industry and real estate...more
Welcome to November’s edition of the UK Tax Round Up. This month has seen publication of the Finance Bill 2021-22 (what will become the Finance Act 2022) including draft legislation for the basis period reform, UK asset...more
As we draw close to the end of the year, we take a moment to revisit some of the taxation changes announced in the Autumn budget, with some of these being implemented in the upcoming tax year in April 2022. ...more
The Chancellor presented the Budget on 27 October. Although it contained a wide range of general spending and tax-related announcements, there was nothing of significance for the private funds industry that had not been...more
The Chancellor of the Exchequer delivered the United Kingdom (UK) Autumn Budget for 2021 on 27 October 2021. The Budget was delivered against the backdrop of the UK’s ongoing recovery from the Covid-19 pandemic and the...more
This is likely to be a key reflection when considering the details issued in July about the new UK holding company regime for “qualifying asset holding companies” (QAHCs). The new regime is intended to make the UK more...more
Draft legislation for Finance Bill 2022 (the "Bill") was published on 20 July 2021. One of the main pieces of draft legislation included in the Bill is the introduction of a new tax regime for asset holding companies (the...more
On 20 July 2021, the UK government published further details of, and draft legislation for, a new elective tax regime for alternative fund structures. Although certain aspects have yet to be clarified, the proposals have...more
Certain UK incorporated holding companies of banks and investments firms will, for the first time, be required to obtain PRA authorisation in 2021. The required applications for authorisation are detailed and will require...more
28 June 2021 is the deadline for UK Financial Holding Companies ("FHC") and Mixed Financial Holding Companies ("MFHC") to submit their application for approval or exemption under the UK's implementation of the Capital...more
The UK Government’s public consultation on Asset Holding companies (AHCs) has just finished, having run from December 15, 2020 to February 23, 2021. The objectives of the UK Government in the consultation have been to improve...more
HM Treasury call for input on review of UK funds regime - HM Treasury has published a call for input on its review of the UK funds regime, covering tax, relevant areas of regulation and opportunities for reform....more
COVID-19 Developments - Tax exemptions for coronavirus antigen costs - Draft regulations providing for employee and employer national insurance contribution (NIC) exemptions from payments made to employees to cover...more