Private equity funds

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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
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
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 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 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 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
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

Most recent Private equity funds content

Practice notes
This Practice Note describes the role and tax treatment applicable to the general partner in a UK limited partnership private equity fund. It...
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Produced in partnership with Emily Clark of Travers Smith 14th Apr
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 of Travers Smith 14th Apr
Practice notes
This Practice Note sets out what to look for when reviewing a private equity fund limited partnership agreement (LPA) from a tax perspective. It is...
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Produced in partnership with Catherine Sear of Proskauer Rose 14th Apr
Practice notes
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...
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Produced in partnership with Emily Clark of Travers Smith 14th Apr
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 of Travers Smith 14th Apr
Practice notes
Private equity backed companiesThe issues facing private equity backed companies when using shares to incentivise employees are similar to those faced...
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Produced in partnership with Becky Rees of Parisi Tax LLP 9th Apr
Practice notes
IP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit transition/implementation period entered into following the UK’s...
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Produced in partnership with Ceinwen Rees and Penny Van den Brande of Macfarlanes LLP 9th Apr
Practice notes
The income-based carried interest (IBCI) rules form part of the legislation which governs the tax treatment of rewards received by fund managers. The...
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9th Apr
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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Produced in partnership with Catherine Sear of Proskauer Rose 9th Apr
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 of Travers Smith 9th Apr
Practice notes
This Practice Note considers the application of stamp duty and stamp duty reserve tax (SDRT) to the transfer of interests in private equity...
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Produced in partnership with Emily Clark of Travers Smith 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
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...
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Produced in partnership with Emily Clark of Travers Smith 29th Mar
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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15th Feb
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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15th Feb
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 Nov

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