News & Analysis as of

United Kingdom Private Equity International Tax Issues

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

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

Proskauer Rose LLP

UK Tax Round Up - February 2021

Proskauer Rose LLP on

UK Case Law Developments - EIS relief not available for shares carrying preferential rights - The Upper Tribunal (UT) in Foojit v HMRC dismissed the taxpayer’s appeal against the First-tier Tribunal’s (FTT’s) decision...more

Proskauer Rose LLP

UK Tax Round Up - December 2020

Proskauer Rose LLP on

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

Proskauer - Tax Talks

High Court decision highlights importance of ensuring claims notices include required information

Proskauer - Tax Talks on

In Dodika Ltd & Ors v United Luck Group Holdings Limited, the High Court (HC) has accepted the sellers’ argument that a notice of a tax claim under a tax covenant served on them by the buyer was invalid because it did not...more

Proskauer Rose LLP

UK Tax Round Up - February 2020

Proskauer Rose LLP on

UK General Tax Developments - HMRC updates to the private sector IR35 rules - On 7 February 2020, HMRC confirmed that the new private sector IR35 rules will only apply to payments made for services provided on or...more

Proskauer Rose LLP

UK Tax Round Up - January 2020

Proskauer Rose LLP on

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

Proskauer Rose LLP

UK Tax Round Up - December 2019

Proskauer Rose LLP on

UK Case Developments - IR35 – no mutuality of obligation to create a contract of employment - RALC Consulting Ltd v HMRC has provided the First-tier Tribunal (FTT) with another opportunity to consider the application...more

Proskauer Rose LLP

UK Tax Round Up - October 2019

Proskauer Rose LLP on

UK Case Law Developments - Reliance on HMRC's manual statement can, but didn't, give rise to legitimate expectation - In the recent judicial review case of Roao Aozora GMAC Investment Ltd v HMRC, the Court of Appeal...more

Proskauer Rose LLP

UK Tax Round Up - September 2019

Proskauer Rose LLP on

Case Law Developments - Place of supply for VAT purposes - The recent case of American Express Services Europe Limited (AESEL) v HMRC is a useful reminder of the well-established two-stage approach to determining the...more

Proskauer Rose LLP

UK Tax Round Up - April 2019

Proskauer Rose LLP on

UK Case Law Developments - Damages on share sales same as on other sales - In Oversea Chinese Banking Corporation Ltd v ING Bank NV, the Commercial Court has held that the measure of damages for breach of warranty in...more

Latham & Watkins LLP

Globally Taxing Issues for Private Equity

Latham & Watkins LLP on

Tax has, in recent months, become a frontpage issue with reaction to businesses not “paying their fair share” sitting alongside pressure on government finances and an uncertain political environment. In our view, the...more

12 Results
 / 
View per page
Page: of 1

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
- hide
- hide