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Practice notes
Unilateral relief, like double tax relief, aims to relieve double taxation. Subject to certain conditions being satisfied and specific limits,...
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9th Nov
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 9th Nov
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 9th Nov
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 9th Nov
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 9th Nov
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 9th Nov
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 Enterprise Investment Scheme (EIS) is designed to encourage investment in smaller, higher-risk trading companies by offering a range of tax...
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9th Nov
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
Practice notes
This Practice Note:•explains:◦the purpose of the tax indemnity clause that is normally found in a loan agreement, and◦that the standard drafting of...
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9th Nov

Most recent Funds content

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 25th Nov
Practice notes
Carried interest (or carry) is a subordinated, contingent right to share in the 'super-profit' of a private equity fund. It is typically held by...
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Produced in partnership with Emily Clark 2nd Nov
Practice notes
This Practice Note describes the tax code applicable to fund managers—the disguised investment management fee (DIMF) rules. In particular, it...
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Produced in partnership with Emily Clark 2nd Nov
Precedents
[Team Leader][insert HMRC address][insert date]Application for clearances in advance under [section[s] 138[ and 139(5)] Taxation of Chargeable Gains...
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20th Oct
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 1st Oct
Practice notes
FORTHCOMING CHANGE: The UK government announced in its Spring Budget 2020 that over the course of 2020 it will be reviewing the UK funds regime, and...
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Produced in partnership with Michael Alliston 29th Sep
Practice notes
This Practice Note provides an introduction to the structuring considerations relevant to a typical offshore private equity fund with some UK...
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Produced in partnership with Ceinwen Rees and Penny Van den Brande of Macfarlanes LLP 29th Sep
Practice notes
This Practice Note:•illustrates the partnership structure of a typical onshore limited partnership fund•explains what carried interest is,...
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Produced in partnership with Emily Clark 29th Sep
Q&As
It is possible for an employee (or director) and employer to make a joint election under section 431 of the Income Tax (Earnings and Pensions) Act...
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29th Sep
Q&As
This Q&A assumes that the client is not treated as an employee for UK tax purposes. It also assumes that the client is a UK-resident and UK-domiciled...
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29th Sep
Q&As
When considering offering shares to employees, whether directly and/or pursuant to a share plan, employer companies and company shareholders need to...
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28th Sep
Q&As
For a single UK company to be a UK real estate investment trust (REIT) in an accounting period, certain conditions need to be met throughout that...
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28th Sep
Practice notes
Jurisdictions coveredThe following jurisdictions are covered in this report:Cayman Islands; France; Germany; Greece; Hong Kong; Ireland; Japan;...
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27th Sep
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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26th Sep
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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26th Sep
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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26th Sep
Practice notes
Brexit: As of exit day (31 January 2020) the UK is no longer an EU Member State. However, in accordance with the Withdrawal Agreement, the UK has...
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26th Sep
Practice notes
This Practice Note examines the tax treatment of UK real estate investment trusts (UK REITs) and their shareholders.The purpose of the UK REIT regime...
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Produced in partnership with Charles Goddard of Rosetta Tax 26th Sep
Practice notes
The UK real estate investment trust (REIT or UK REIT) regime applies both to sole companies and to groups of companies. In practice, however, the...
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Produced in partnership with Charles Goddard of Rosetta Tax 26th Sep
Practice notes
This Practice Note examines the principal anti-avoidance provisions which apply to companies and groups of companies within the UK REIT regime.These...
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Produced in partnership with Charles Goddard of Rosetta Tax 26th Sep

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