Private equity funds

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Practice notes
VAT—what is a transfer of a business as a going concern?IP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit...
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Produced in partnership with Cathya Djanogly 19th May
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
What is an intangible fixed asset?Part 8 of the Corporation Tax Act 2009 (CTA 2009) is a specific corporation tax regime that applies exclusively to...
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Produced in partnership with Anne Fairpo of Temple Tax Chambers 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—direct tax treatment of a Jersey property unit trust (JPUT)STOP PRESS relating to property rich collective investment...
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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
Practice notes
FATCA in the UK—the UK:US Intergovernmental Agreement: an outlineIP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit...
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Produced in partnership with Ali Kazimi and Chris Orchard of Hansuke Consulting Limited 19th May
Practice notes
Tax considerations on a loan agreement—the tax gross up clauseIP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit...
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Produced in partnership with Eloise Walker of Pinsent Masons 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
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
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
Why have a tax covenant?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...
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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
Transfer of a trade under common ownershipSometimes the restructuring of a business will involve a company transferring an existing trade to a...
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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 Private equity funds content

Practice notes
VAT issues for private equity fundsThis Practice Note looks at VAT issues arising in the context of private equity funds. It considers the VAT...
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Produced in partnership with Emily Clark of Travers Smith 2nd 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 24th Jun
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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6th Jun
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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6th Jun
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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5th Jun
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 5th Jun
Practice notes
Reviewing the tax aspects of a private equity fund limited partnership agreementThis Practice Note sets out what to look for when reviewing a private...
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Produced in partnership with Catherine Sear of Proskauer Rose 5th Jun
Practice notes
How are employees taxed when they acquire carried interest?This Practice Note:•illustrates the partnership structure of a typical onshore limited...
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Produced in partnership with Emily Clark of Travers Smith 5th Jun
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 5th Jun
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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5th Jun
Practice notes
What is the role and tax treatment of the general partner in a PE fund?This Practice Note describes the role and tax treatment applicable to the...
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Produced in partnership with Emily Clark of Travers Smith 5th Jun
Practice notes
Taxation of private equity funds—how is a fund structured?This Practice Note provides an introduction to the structure of a typical onshore private...
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Produced in partnership with Emily Clark of Travers Smith 5th Jun
Practice notes
Understanding the tax disclosure in a fund Private Placement Memorandum (PPM)To seek out investors, a private equity fund will use a private placement...
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Produced in partnership with Catherine Sear of Proskauer Rose 5th Jun
Practice notes
Stamp duty and SDRT on transfers of interests in private equity partnershipsThis Practice Note considers the application of stamp duty and stamp duty...
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Produced in partnership with Emily Clark of Travers Smith 5th Jun
Practice notes
How are investors in a private equity fund taxed on their share of the profits?This Practice Note sets out how the investors in a typical UK private...
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Produced in partnership with Emily Clark of Travers Smith 5th Jun
Practice notes
Disguised investment management fee rulesThis Practice Note describes the tax code applicable to fund managers—the disguised investment management fee...
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Produced in partnership with Emily Clark of Travers Smith 5th Jun

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