News & Analysis as of

Taxation Investment Funds United Kingdom

McDermott Will & Schulte

Carried interest in the UK: The new average holding period (AHP) condition for credit funds

The UK tax regime for carried interest is being substantially revised from April 2026. This Alert focuses on one particular aspect: the changes to how credit funds should calculate the average holding period (AHP) of their...more

Carey Olsen

Guernsey funds – special considerations for US managers

Carey Olsen on

Guernsey, located in the English Channel, is one of the world’s largest offshore finance centres, with a thriving funds industry. The value of funds under management and administration in Guernsey is US$532bn. Guernsey is an...more

Hogan Lovells

UK carried interest regime: draft legislation confirms scope and conditions

Hogan Lovells on

On 21 July 2025, the UK Government published draft legislation for the new UK carried interest regime, which is expected to come into effect from 6 April 2026. As previously announced, the draft legislation provides for...more

Latham & Watkins LLP

The UK’s New Regime for Carried Interest Taxation - How the Draft Legislation Stacks Up

Latham & Watkins LLP on

On 21 July 2025, the UK government published draft legislation relating to its new carried interest regime. This Client Alert considers key aspects of the new regime and how it may apply to UK-based asset managers and non-UK...more

Skadden, Arps, Slate, Meagher & Flom LLP

UK Government Targets Reform of the Investment Manager Exemption

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

Proskauer Rose LLP

UK Tax Round Up - April 2025

Proskauer Rose LLP on

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

Ropes & Gray LLP

Impact of Permanent Establishment Reform for Credit Funds

Ropes & Gray LLP on

On 28 April, the UK Government produced draft legislation for consultation as the latest step in the reform of UK rules on transfer pricing, permanent establishments and diverted profits tax. From an asset management...more

Cadwalader, Wickersham & Taft LLP

The New UK Reserved Investor Fund: RIFs and QAHCs Create an Ambitious UK Structuring Toolkit

Introduction - After a long gestation, the much heralded new UK fund structure, the Reserved Investor Fund (“RIF”) is finally expected to be available from 19 March 2025....more

Alston & Bird

A New UK Tax Regime for Asset Holding Companies

Alston & Bird on

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

White & Case LLP

Taxation of Asset Holding Companies – A New Regime

White & Case LLP on

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

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