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Practice notes
Property authorised investment funds (PAIFs)—summaryThe regime for property authorised investment funds (PAIFs) was introduced in 2008.It created a...
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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 19th May
Practice notes
Direct tax treatment of damages and compensation paymentsWhere a dispute is brought to an end by a payment of damages or compensation, whether under a...
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19th May
Practice notes
Share sale or asset sale—tax considerationsThe sale of a company's business can be structured as either:•a sale of assets owned by the company (an...
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19th May
Practice notes
SDLT—deeds of rectificationStamp duty land tax (SDLT) ceased to apply to any land transaction involving any interests in or over land in Scotland from...
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19th May
Practice notes
UK Crown Dependency/Overseas Territory Agreements (CDOT)—FAQsWhat are the CDOT agreements?The UK entered into agreements with its three Crown...
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Produced in partnership with Ali Kazimi of Hansuke 19th May
Practice notes
VAT treatment of damages and compensation paymentsFORTHCOMING CHANGE: HMRC is in the process of revising Revenue and Customs Brief 12 (2020) on the...
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19th May
Practice notes
Property holding structures—SDLT and VAT treatment of a Jersey Property Unit Trust (JPUT)IP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the...
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19th May
Practice notes
Commercial service charges—VAT implicationsThis Practice Note is about the VAT treatment of non-residential service charges. General positionService...
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Produced in partnership with Martin Scammell 19th May
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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19th May
Practice notes
Section 198 and 199 elections on transactions involving real estateThis Practice Note describes the law and practice relating to elections under...
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Produced in partnership with Martin Wilson 19th May
Practice notes
Taxation of UK LLPsA UK limited liability partnership (LLP) is a body corporate for company law purposes, but is generally taxed as though it were a...
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19th May
Practice notes
The Budget and Finance Bill processThe Budget is a Parliamentary event at which the Chancellor of the Exchequer makes important announcements relating...
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19th May
Practice notes
Capital reduction demergersThe reasons why a company might carry out a demerger, and the different ways in which a demerger may be structured, are...
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Produced in partnership with Zoe Feller of Bird & Bird 19th May
Q&As
Corporate redomiciliation—can a non-UK company redomicile into the UK?It is possible for a non-UK incorporated company to redomicile to the UK....
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19th May
Practice notes
R&D capital allowancesFORTHCOMING CHANGE: At Spring Budget 2021, the government announced a wide-ranging review of research and development (R&D)...
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Produced in partnership with Anne Fairpo of Temple Tax Chambers 19th May
Practice notes
SDLT group reliefFORTHCOMING CHANGE relating to FA 2008, Sch 36: In its Tax Information and Impact Note (TIIN) on freeports, the government announced...
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19th May

Most recent Funds content

Q&As
Is there anything that prevents an authorised contractual scheme from being treated as carrying on a trade in the UK, and investors therefore being...
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1st Aug
Q&As
What is the tax treatment for a situation where, due to poor performance of future deals within a fund, there is a clawback of the carried interest...
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1st Aug
Q&As
If a UK real estate investment trust (REIT) wishes to convert existing shares into restricted preference shares, what conditions must be met for the...
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1st Aug
Q&As
Does HMRC need to be notified of a section 431 of the Income Tax (Earnings and Pensions) Act 2003 election?It is possible for an employee (or...
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1st Aug
Q&As
When making a section 431 election under the Income Tax (Earnings and Pensions) Act 2003, is it necessary to obtain a professional valuation, or can...
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1st Aug
Practice notes
Getting the Deal Through: Fund Management 2020Jurisdictions coveredThe following jurisdictions are covered in this report:Cayman Islands; France;...
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31st Jul
Practice notes
Income-based carried interest rulesThe income-based carried interest (IBCI) rules form part of the legislation which governs the tax treatment of...
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31st Jul
Practice notes
Taxation of authorised investment funds (AIFs)—what are they?An authorised investment fund (AIF) is a variety of collective investment scheme (CIS)....
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Produced in partnership with Camilla Spielman 31st Jul
Practice notes
Taxation of investment trusts—tax treatment of the fund and its investorsAn investment trust is a listed pooled investment vehicle in the form of a UK...
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Produced in partnership with Michael Alliston 31st Jul
Practice notes
UK REITs—taxation of the REIT and shareholdersFORTHCOMING CHANGE: Finance Bill 2022 will amend the real estate investment trust (REIT) regime. The...
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Produced in partnership with Martin Shah of Simmons & Simmons and Charles Goddard of Rosetta Tax 31st Jul
Practice notes
Taxation of offshore funds—non-reporting offshore fundsA 'non-reporting offshore fund' is any offshore fund which does not have reporting fund status...
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Produced in partnership with Michael Alliston 31st Jul
Practice notes
PAIFs—taxation of the schemeThe tax regime for Property Authorised Investment Funds (PAIFs) is designed to create an open-ended collective investment...
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Produced in partnership with Martin Shah and Charles Goddard of Rosetta Tax 31st Jul
Practice notes
Taxation of carried interest holders in a private equity fundCarried interest (or carry) is a subordinated, contingent right to share in the...
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Produced in partnership with Emily Clark of Travers Smith 31st Jul
Practice notes
Taxation of offshore funds—entry into the reporting fund regimeA ‘reporting fund’ is an offshore fund that has been approved as a reporting fund, and...
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Produced in partnership with Michael Alliston 31st Jul
Practice notes
Taxation of international private equity funds—offshore fund structuringThis Practice Note provides an introduction to the structuring considerations...
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Produced in partnership with Ceinwen Rees and Penny Van den Brande of Macfarlanes LLP 31st Jul
Practice notes
Incentivising employees in private equity owned businessesPrivate equity backed companiesThe issues facing private equity backed companies when using...
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Produced in partnership with Becky Rees of Parisi Tax LLP 31st Jul
Practice notes
Taxation of offshore funds—requirements of the reporting funds regimeUK investors in ‘reporting’ offshore funds are charged to tax on their share of...
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Produced in partnership with Michael Alliston 31st Jul
Practice notes
Taxation of hedge funds—hedge fund managers and the management structureWhen considering the fund management structure for a hedge fund, the structure...
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Produced in partnership with James McCredie and Alicia Thomas of Macfarlanes LLP 31st Jul
Practice notes
Taxation of hedge funds—trading in the UK and the investment manager exemption (IME)A hedge fund will typically be established as a non-UK company...
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Produced in partnership with James McCredie and Alicia Thomas of Macfarlanes LLP 31st Jul
Practice notes
Taxation of investment trusts—liquidations and reconstructionsInvestments trusts are often structured as companies without a fixed life, meaning that...
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Produced in partnership with Michael Alliston 31st Jul

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