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United Kingdom Taxation

Proskauer Rose LLP

UK Tax Round Up - July 2025

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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

Carey Olsen

Guernsey funds – special considerations for US managers

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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

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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

Hogan Lovells

UK Pensions and Inheritance Tax (IHT): Revised Policy from HMRC

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HMRC has taken on board concerns from the pensions industry about its previous proposals for bringing many pension death benefits within the scope of inheritance tax (IHT). On 21 July 2025, HMRC issued a Policy Paper and...more

Latham & Watkins LLP

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

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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

Cadwalader, Wickersham & Taft LLP

Beard v HMRC: Capital Dividends. A Triumph of Form Over Substance?

Introduction The recent UK Court of Appeal decision in Beard considered the treatment of dividends from a non-UK company, particularly the interpretation of ‘dividends of a capital nature’. In her leading judgment, Falk LJ...more

Mayer Brown

Inheritance Tax on Pension Death Benefits – Revised Proposals

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The government has responded to its consultation on its proposal that from 6 April 2027, most death benefits paid from registered pension schemes (whether DB or DC) will form part of the deceased member’s estate for...more

Skadden, Arps, Slate, Meagher & Flom LLP

Towards Commercial Rationality: HMRC’s New Unilateral APA Process Will Reduce Uncertainty Over Cost-Sharing Participation

Multinational groups adopting cost contribution arrangements (CCAs) — or cost share agreements in US parlance — as part of their cross-border intellectual property (IP) development strategies have a new opportunity to...more

Proskauer Rose LLP

UK Tax Round Up - June 2025

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Welcome to the June edition of our UK Tax Round Up, which discusses HMRC’s response to its consultation on the new UK carried interest regime to be introduced next year and interesting cases on the main purpose test in the...more

Mayer Brown

Recovery of VAT on DB Pension Scheme Investment Costs – New HMRC Policy

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HMRC has announced a new policy on the recovery by employers of VAT charged on investment services provided to their DB pension schemes. Until 18 June 2025, the extent to which an employer could recover any VAT paid on...more

Wilson Sonsini Goodrich & Rosati

FAQs: UK Employee Equity Incentive Annual Reporting and EMI Notification Deadline Fast Approaching

Companies operating employee equity incentive arrangements in the UK, including companies incorporated or registered outside of the UK, are mandated to file an online annual return with HM Revenue & Customs (HMRC) no later...more

Wilson Sonsini Goodrich & Rosati

Key UK Tax Implications of the Delaware Flip

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

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

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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

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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

Asset Disposals in the "Real World"

The recent case of A Sajedi and others v HMRC [2025] UKFTT 297 (TC) in the UK First-tier Tribunal (“FTT”) is an interesting example of a UK taxation tribunal intervening to decide a litigated matter on grounds that neither...more

Dickinson Wright

Have You Considered London

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London always has and continues to be a popular destination for overseas companies. Listing in London provides access to the largest capital market in Europe with a deep pool of liquidity and international investors,...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

Morrison & Foerster LLP

UK’s Carried Interest Tax Hike and More Changes Proposed for Fund Managers in 2026

The Chancellor of the Exchequer, Rachel Reeves, delivered her first Budget Statement on 30 October. The Autumn Budget drew widespread attention, with several measures grabbing the headlines, including the historic fact that...more

Walkers

A Guide to debt securities issuers in Jersey

Walkers on

Jersey is a well-established jurisdiction of choice for issuing debt securities in international finance transactions. Recently, we have seen a steady increase in interest in Jersey debt securities issuers either for a...more

Proskauer - Tax Talks

UK government consults on taxation of carried interest

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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

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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

Skadden, Arps, Slate, Meagher & Flom LLP

The London Space Law Symposium

On 9 May 2024, Skadden held the inaugural London Space Law Symposium, where six panels of Skadden representatives and industry experts discussed legal aspects of the new space economy. The event was held in the Naim Dangoor...more

Proskauer Rose LLP

UK Tax Round Up - March 2024

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Welcome to March’s edition of our UK Tax Round Up. This month has seen a number of interesting cases covering a range of issues, from the deductibility of costs against employment income to the place of effective management...more

A&O Shearman

UK carbon border adjustment mechanism: shaping up ahead of 2027

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In 2027, the UK will introduce a carbon border adjustment mechanism (CBAM) on imports of certain carbon intensive goods. The CBAM will impose a charge on the emissions embodied in relevant imports that take place on or after...more

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