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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 12th Jan
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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Produced in partnership with Martin Shah and Gary Barnett of Simmons & Simmons LLP 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
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 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
A damages or compensation payment may attract VAT. This depends on exactly what the payment is for. If it is purely compensatory, it will be outside...
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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 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
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 Hedge funds content

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
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 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 of Travers Smith 9th Apr
Practice notes
A hedge fund will typically be established as a non-UK company that is resident outside the UK for tax purposes. For more on the legal structure...
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Produced in partnership with James McCredie and Alicia Thomas of Macfarlanes LLP 9th Apr
Practice notes
Jurisdictions coveredThe following jurisdictions are covered in this report:Cayman Islands; France; Germany; Greece; Hong Kong; Ireland; Japan;...
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9th Apr
Practice notes
This Practice Note examines a number of additional tax issues that should be considered in relation to hedge fund structuring that are not...
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Produced in partnership with James McCredie and Alicia Thomas of Macfarlanes LLP 2nd Mar
Practice notes
Although there is no specific definition of the term ‘hedge fund’, there are a number of characteristics that might typically cause a fund to be...
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Produced in partnership with James McCredie and Alicia Thomas of Macfarlanes LLP 26th Feb

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