This Practice Note explains how the disguised investment management fee (DIMF) rules work. It explains the main planning arrangements targeted by the DIMF rules and explores how the rules operate in practice. Produced in partnership with Emily Clark of Travers Smith
This Practice Note describes the taxation of employees who acquire carried interest (or carry) in a private equity fund. It considers the application of the employment-related securities rules, including the restricted securities rules, section 431 elections and the 2003 Carry MoU. There is also a brief explanation of the PAYE and National Insurance contributions (NICs) consequences arising in respect of a carried interest holding. This Practice Note was produced in partnership with Emily Clark of Travers Smith.
This Practice Note explains how investors in a private equity fund are taxed on their interest and share of the fund's profits. Tax transparent structures mean each investor is treated as if they owned their share of the PE fund's investments directly. This Practice Note considers the nature of the profits and status of each investor and summarises key anti-avoidance provisions: attribution of gains; transfer of assets abroad; and the offshore funds rules. Produced in partnership with Emily Clark of Travers Smith.
This Practice Note considers the application of stamp duty and stamp duty reserve tax (SDRT) to the transfer of interests in private equity partnerships. The note considers the stamp duty rules, and, in particular, whether the transfer of a partnership interest is stampable; the consequences of not stamping; whether it matters that the partnership is a UK partnership or a foreign partnership; and how stamp duty is calculated. It then examines whether the SDRT rules apply to partnership transfers. This Practice Note was produced in partnership with Emily Clark of Travers Smith.
This Practice Note looks at the taxation of holders of carried interest (or carry) in a UK private equity fund. It sets out the the structure of, and need for, a separate carried interest partner and considers the impact of the disguised investment management (DIMF) rules and the incomes-based carried interest (IBCI) rules. This Practice Note was produced in partnership with Emily Clark of Travers Smith.
This Practice Note is an introductory note for tax lawyers on how a typical onshore private equity fund is structured. The note sets out what a private equity fund is and who the typical investors are (mainly institutional investors seeking long-term capital growth). The Practice Note illustrates how a typical fund is structured and explains the role of each of the entities in the structure. It also sets out common terms of a private equity fund and key documents required to set up the fund. This Practice Note was produced in partnership with Emily Clark of Travers Smith.
This Practice Note deals with VAT and private equity funds. It considers the VAT implications of dealings between a limited partnership fund and its partners by looking at whether making an investment into the fund or transferring an interest in the fund involves a taxable supply. It also considers whether VAT should be charged on the supply of advice and management services to the fund. This Practice Note was produced in partnership with Emily Clark of Travers Smith.
This Practice Note describes the role and tax treatment of the general partner in a private equity fund. It explains the importance of and the role played by the general partner, how the general partner is remunerated and funds a management fee in the early years of the fund and considers the tax treatment of fund and management expenses together with the tax status of the management fee. It also sets out key considerations for a non-UK fund and special issues where the fund is a Scottish limited partnership or a limited liability partnership. This Practice Note was produced in partnership with Emily Clark of Travers Smith.
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