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Practice notes
FORTHCOMING CHANGE: HMRC is consulting (13 July to 10 August 2020) on draft regulations to provide a deduction from a UK entity’s equity and...
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Produced in partnership with Charlotte Sallabank of Katten Muchin Rosenman UK LLP 12th Jan
Practice notes
Plant and machinery allowances are the most widely used form of capital allowance. Plant and machinery is often (wrongly) interpreted as if the terms...
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Produced in partnership with Martin Wilson 12th Jan
Practice notes
It is market practice for a tax covenant, also known as a tax deed, to form part of the transaction documents in respect of a sale of all the shares...
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9th Nov
Practice notes
The reasons why a company might carry out a demerger, and the different ways in which a demerger may be structured, are described in Practice Notes:...
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Produced in partnership with Zoe Feller of Bird & Bird 12th Jan
Practice notes
This Practice Note describes the law and practice relating to elections under section 198 or 199 of the Capital Allowances Act 2001 (CAA 2001), which...
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Produced in partnership with Martin Wilson 12th Jan
Practice notes
It is standard market practice for loan agreements (also known as facility agreements), whether bilateral or syndicated, to:•prohibit a borrower from...
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Produced in partnership with Eloise Walker of Pinsent Masons 12th Jan
Practice notes
Coronavirus (COVID-19): HMRC has stated in its International Manual that if a financial institution cannot meet the FATCA reporting deadline of 31 May...
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Produced in partnership with Ali Kazimi and Chris Orchard of Hansuke Consulting Limited 12th Jan
Practice notes
This Practice Note is about the meaning of a scheme of reconstruction for tax purposes.Tax neutrality is maintained where a company (company A) enters...
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9th Nov
Practice notes
This Practice Note explains:•what a determination in respect of direct tax (ie a direct tax determination) is•when HMRC might issue a direct tax...
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Produced in partnership with Philip Rutherford 12th Jan
Practice notes
Where a dispute is brought to an end by a payment of damages or compensation, whether under a court order or an out-of-court settlement agreement:•the...
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9th Nov
Practice notes
Overdrafts, term loans and revolving credit facilitiesThree common types of loan facility are:•overdrafts•term loans, and•revolving credit facilities...
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9th Nov
Practice notes
The regime for property authorised investment funds (PAIFs, or as HMRC use in regulations and their published guidance, Property AIFs)) was introduced...
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Produced in partnership with Martin Shah of Simmons & Simmons LLP based on material originally written by Charles Goddard of Rosetta Tax LLP 12th Jan
Practice notes
The value shifting rules are anti-avoidance provisions. They are similar to the rules applying to depreciatory transactions in that they target the...
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9th Nov
Precedents
1 Withholding and grossing up 1.1 All sums payable under this [Agreement] by or on behalf of any party (for the...
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9th Nov
Practice notes
A management buyout, or MBO, involves the acquisition of a business by its existing management team usually with the help of private equity financing....
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9th Nov
Practice notes
The international movement of capital rules should be considered whenever:•any non-UK tax resident subsidiary (referred to in this note as a foreign...
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9th Nov

Most recent Funds content

Practice notes
The intention of the tax regime for property authorised investment funds (PAIFs) is to tax investors in a similar way to those that invest directly in...
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Produced in partnership with Martin Shah of Simmons & Simmons LLP based on material originally written by Charles Goddard of Rosetta Tax LLP 13th Apr
Practice notes
This Practice Note sets out what to look for when reviewing a private equity fund limited partnership agreement (LPA) from a tax perspective. It is...
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Produced in partnership with Catherine Sear of Proskauer Rose 13th Apr
Practice notes
In order for a Property Authorised Investment Fund (PAIF)to operate within the PAIF regime without incurring additional tax charges or other...
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Produced in partnership with Martin Shah of Simmons & Simmons LLP based on material originally written by Charles Goddard of Rosetta Tax LLP 13th Apr
Practice notes
Private equity backed companiesThe issues facing private equity backed companies when using shares to incentivise employees are similar to those faced...
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Produced in partnership with Becky Rees of Parisi Tax LLP 9th Apr
Practice notes
This Practice Note looks at the rules that apply to the taxation of authorised investment funds (AIFs), which is the collective term used for certain...
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Produced in partnership with Camilla Spielman 9th Apr
Practice notes
IP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit transition/implementation period entered into following the UK’s...
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Produced in partnership with Ceinwen Rees and Penny Van den Brande of Macfarlanes LLP 9th Apr
Practice notes
This Practice Note summarises the main practical uses of unauthorised unit trusts (UUTs) and some of the common issues that arise in those...
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9th Apr
Practice notes
This Practice Note discusses a type of UK authorised investment fund called an authorised contractual scheme (ACS). It provides a description of the...
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Produced in partnership with Gordon Gray of KPMG 9th Apr
Practice notes
As discussed in Practice Note: Taxation of investment trusts—what is an investment trust?, a company must satisfy certain eligibility conditions and...
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Produced in partnership with Michael Alliston 9th Apr
Practice notes
This Practice Note looks at the typical legal structure of a hedge fund vehicle.For what hedge funds are, and the particular characteristics that all...
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Produced in partnership with James McCredie and Alicia Thomas of Macfarlanes LLP 9th Apr
Practice notes
This Practice Note provides an introduction to the structure of a typical onshore private equity fund. In particular, it explains:•what a private...
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Produced in partnership with Emily Clark of Travers Smith 9th Apr
Practice notes
The income-based carried interest (IBCI) rules form part of the legislation which governs the tax treatment of rewards received by fund managers. The...
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9th Apr
Practice notes
What is an unauthorised unit trust (UUT)?Unit trusts, as a vehicle-type, are chiefly used as investment vehicles. An ‘unauthorised’ unit trust (UUT)...
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9th Apr
Practice notes
An investment trust is a listed pooled investment vehicle in the form of a UK tax resident company (despite the name, it is not a trust). Investment...
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Produced in partnership with Michael Alliston 9th Apr
Practice notes
A ‘reporting fund’ is an offshore fund that has been approved as a reporting fund, and which has not left the reporting fund regime (voluntarily or by...
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Produced in partnership with Michael Alliston 9th Apr
Practice notes
The regime for property authorised investment funds (PAIFs, or as HMRC use in regulations and their published guidance, Property AIFs)) was introduced...
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Produced in partnership with Martin Shah of Simmons & Simmons LLP based on material originally written by Charles Goddard of Rosetta Tax LLP 9th Apr
Practice notes
To seek out investors, a private equity fund will use a private placement memorandum (PPM) as its main marketing document. The content of a PPM is...
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Produced in partnership with Catherine Sear of Proskauer Rose 9th Apr
Practice notes
A tax elected fund (TEF) is an authorised investment fund (AIF) that meets certain conditions and whose application to be treated as a TEF is accepted...
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Produced in partnership with Martin Shah 9th Apr
Practice notes
When considering the fund management structure for a hedge fund, the structure of the hedge fund itself, and in particular the jurisdiction in which...
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Produced in partnership with James McCredie and Alicia Thomas of Macfarlanes LLP 9th Apr
Practice notes
This Practice Note sets out how the investors in a typical UK private equity fund might be subject to UK taxation on their share of the fund's...
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Produced in partnership with Emily Clark of Travers Smith 9th Apr

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