News & Analysis as of

Taxation Tax Reform 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

K&L Gates LLP

Europe: Fundamental Reform of UK Taxation of Carried Interest

K&L Gates LLP on

From 6 April 2026, carry will be redefined and taxed in the United Kingdom as deemed UK trade or business income where investment management services (as redefined) are performed in the UK. The relevant draft legislation was...more

Proskauer Rose LLP

UK Tax Round Up - July 2025

Proskauer Rose LLP on

Welcome to July’s edition of our UK Tax Round Up. Apart from the draft legislation and accompanying material released on 21 July as part of “L-Day” (legislation day), July was a fairly quiet month for UK tax developments....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

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 - Tax Talks

UK government consults on taxation of carried interest

Proskauer - Tax Talks on

The newly elected UK Labour government published its call for evidence (see link here) on the taxation of carried interest on Monday 29 July 2024. This consultation by HM Treasury, cautiously anticipated following statements...more

Proskauer - Tax Talks

UK Supreme Court confirms no deduction for expenses related to share and asset sale

Proskauer - Tax Talks on

On 16 July 2024, the UK Supreme Court (SC) published its judgment in the case of Centrica Overseas Holdings Ltd (COHL) v HMRC. The ruling addresses the issue of whether professional advisory fees incurred in contemplation of...more

McDermott Will & Schulte

UK Government Announce Abolition of UK Non-Dom Tax Status and Changes to Come for Inheritance Tax

On 6 March 2024, the UK government announced the planned abolition of the remittance basis of taxation for UK resident non-domiciliaries from 6 April 2025 onwards for foreign income and gains (FIG). This will be replaced with...more

J.S. Held

The Diverted Profits Tax & Royalty Withholding Tax: Impacts on Intellectual Property Licenses and Transactions

J.S. Held on

The Diverted Profits Tax (DPT) has been a significant area of focus for taxpayers and tax authorities in the UK and Australia. The tax targets specific situations in which taxable profits are alleged to have been “diverted”...more

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