Hedge funds

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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
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
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
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
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
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
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
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
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
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 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
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
FORTHCOMING CHANGE: HMRC is consulting (13 July to 10 August 2020) on draft regulations to provide a deduction from a UK entity’s equity and...
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Produced in partnership with Charlotte Sallabank of Katten Muchin Rosenman UK LLP 12th Jan
Practice notes
Brexit: This Practice Note contains information on subjects impacted by the UK’s withdrawal from the EU. The Taxation (Cross-border Trade) Act 2018,...
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Produced in partnership with John Fuszard of Sagars Accountants Ltd 12th Jan
Practice notes
Stamp duty land tax (SDLT) ceased to apply to any land transaction involving any interests in or over land in Scotland from 1 April 2015. From that...
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9th Nov
Practice notes
Part 8 of the Corporation Tax Act 2009 (CTA 2009) is a specific corporation tax regime that applies exclusively to the gains and losses of intangible...
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Produced in partnership with Anne Fairpo of Temple Tax Chambers 12th Jan

Most recent Hedge funds content

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 26th Apr
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
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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