This Practice Note describes the tax code applicable to fund managers—the disguised investment management fee (DIMF) rules. In particular, it...
This Practice Note: • illustrates the partnership structure of a typical onshore limited partnership fund • explains what carried interest is, and • describes the tax...
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 profits. One of the reasons...
The income-based carried interest (IBCI) rules form part of the legislation which governs the tax treatment of rewards received by fund managers. The IBCI rules attempt...
This Practice Note sets out what to look for when reviewing the tax sections of a private equity fund limited partnership agreement (LPA). It is drafted for...
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 UK levies...
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 members of the private...
This Practice Note provides an introduction to the structuring considerations relevant to a typical offshore private equity fund with some UK connection. The note deals...
This Practice Note provides an introduction to the structure of a typical onshore private equity fund. In particular, it explains: • what a private equity fund is • who...
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 largely governed by...
This Practice Note looks at VAT issues arising in the context of private equity funds. It considers the VAT implications of dealings between a limited partnership fund...
This Practice Note describes the role and tax treatment applicable to the general partner in a UK limited partnership private equity fund. It highlights, in particular: •...