Private equity and venture capital

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The Trade and Cooperation Agreement—implications for business tax

The following Public Law news provides comprehensive and up to date legal information on The Trade and Cooperation Agreement—implications for business tax

Retained EU law—a guide for the perplexed

The following Banking & Finance news provides comprehensive and up to date legal information on Retained EU law—a guide for the perplexed

Relevant relationship agreement law—a guide for the perplexed

The following Corporate Crime news provides comprehensive and up to date legal information on Relevant relationship agreement law—a guide for the perplexed

FTT applies Ramsay to defeat loss creation scheme (Padfield v HMRC)

The following Private Client news provides comprehensive and up to date legal information on FTT applies Ramsay to defeat loss creation scheme (Padfield v HMRC)

Featured Tax content

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 the gains and losses of intangible...

Property holding structures—direct tax treatment of a Jersey property unit trust (JPUT)

FORTHCOMING CHANGE relating to property rich collective investment vehicles and certain investors: HMRC is consulting until 16 December 2020 on draft...

SDLT—deeds of rectification

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...

VAT—triangulation

Brexit: This Practice Note contains information on subjects impacted by the UK’s withdrawal from the EU. The Taxation (Cross-border Trade) Act 2018,...

Practice notes

Bank levy

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...

Produced in partnership with Charlotte Sallabank of Katten Muchin Rosenman UK LLP 12th Jan

Practice notes

Unilateral relief for foreign tax

Unilateral relief, like double tax relief, aims to relieve double taxation. Subject to certain conditions being satisfied and specific limits,...

9th Nov

Practice notes

Plant and machinery allowances—definition of plant and machinery

Plant and machinery allowances are the most widely used form of capital allowance. Plant and machinery is often (wrongly) interpreted as if the terms...

Produced in partnership with Martin Wilson 12th Jan

Practice notes

VAT on composite supplies

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...

Produced in partnership with Martin Shah and Gary Barnett of Simmons & Simmons LLP 12th Jan

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 sale of all the shares...

9th Nov

Practice notes

Capital reduction demergers

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:...

Produced in partnership with Zoe Feller of Bird & Bird 12th Jan

Practice notes

Section 198 and 199 elections on transactions involving real estate

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...

Produced in partnership with Martin Wilson 12th Jan

Practice notes

Tax considerations on a loan agreement—the tax gross up clause

It is standard market practice for loan agreements (also known as facility agreements), whether bilateral or syndicated, to:•prohibit a borrower from...

Produced in partnership with Eloise Walker of Pinsent Masons 12th Jan

Practice notes

FATCA in the UK—the UK:US Intergovernmental Agreement: an outline

Coronavirus (COVID-19): HMRC has stated in its International Manual that if a financial institution cannot meet the FATCA reporting deadline of 31 May...

Produced in partnership with Ali Kazimi and Chris Orchard of Hansuke Consulting Limited 12th Jan

In-house

Practice notes

Schemes of reconstruction defined

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...

9th Nov

Practice notes

What is a tax determination?

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...

Produced in partnership with Philip Rutherford 12th Jan

Practice notes

EIS funds, including approved knowledge-intensive funds

The Enterprise Investment Scheme (EIS) is designed to encourage investment in smaller, higher-risk trading companies by offering a range of tax...

9th Nov

Practice notes

Property authorised investment funds (PAIFs)—summary

The regime for property authorised investment funds (PAIFs, or as HMRC use in regulations and their published guidance, Property AIFs)) was introduced...

Produced in partnership with Martin Shah of Simmons & Simmons LLP based on material originally written by Charles Goddard of Rosetta Tax LLP 12th Jan

Practice notes

Value shifting

The value shifting rules are anti-avoidance provisions. They are similar to the rules applying to depreciatory transactions in that they target the...

9th Nov

Practice notes

Management buyouts—summary of tax issues for management

A management buyout, or MBO, involves the acquisition of a business by its existing management team usually with the help of private equity financing....

9th Nov

Practice notes

International movement of capital

The international movement of capital rules should be considered whenever:•any non-UK tax resident subsidiary (referred to in this note as a foreign...

9th Nov

Most recent Private equity and venture capital content

Practice notes

Tax on private equity acquisitions—international structuring

IP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit transition/implementation period entered into following the UK’s...

Produced in partnership with Ceinwen Rees and Penny Van den Brande of Macfarlanes LLP 15th Jan

Practice notes

Growth shares (value shares)

What are growth shares?Growth shares, also known as value shares or hurdle shares, are a special class of shares that have restricted rights. These...

15th Jan

Practice notes

Secondary buyouts—capital gains tax issues for the management team

This Practice Note deals with secondary buyouts and examines the application of the capital gains tax (CGT) regime to a disposal of target company...

15th Jan

Practice notes

Growth capital—tax reliefs available to managers

This Practice Note summarises the key UK tax reliefs available to key individuals running a company that is seeking growth (ie seed, venture and...

15th Jan

Practice notes

Taxation of international private equity funds—offshore fund structuring

IP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit transition/implementation period entered into following the UK’s...

Produced in partnership with Ceinwen Rees and Penny Van den Brande of Macfarlanes LLP 15th Jan

Practice notes

Tax on private equity and venture capital—glossary of terms

This glossary sets out the meaning of key terms used when looking at tax issues that arise within the private equity and venture capital industry. For...

15th Jan

Practice notes

Income-based carried interest rules

The income-based carried interest (IBCI) rules form part of the legislation which governs the tax treatment of rewards received by fund managers. The...

15th Jan

Practice notes

Growth capital—tax on management shareholdings

This Practice Note explains how the key people who are running a company seeking growth (ie seed, venture and development) capital will be taxed in...

15th Jan

Practice notes

Management buyouts—tax on management shareholdings

This Practice Note deals with private equity-backed UK management buyouts (MBOs) and examines the employment tax issues arising for a UK management...

15th Jan

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 general partner in a UK limited partnership private equity fund. It...

Produced in partnership with Emily Clark of Travers Smith 15th Jan

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 equity fund might be subject to UK taxation on their share of the fund's...

Produced in partnership with Emily Clark of Travers Smith 15th Jan

Practice notes

Reviewing the tax section of a private equity fund limited partnership agreement

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...

Produced in partnership with Ceinwen Rees of Macfarlanes 15th Jan

Practice notes

Secondary buyouts—tax issues for management

A secondary buyout (SBO) is broadly where a private equity firm buys a business that has previously been subject to a buyout. This Practice Note...

15th Jan

Practice notes

Secondary buyouts—income tax issues for the management team

This Practice Note examines how the income tax regime applies where UK managers dispose of interests in the target company as part of a private...

15th Jan

Practice notes

Buyouts—tax issues on acquisition group borrowing

This Practice Note looks at tax issues arising on money borrowed by the acquisition group to finance a private equity-backed buyout.In the context of...

15th Jan

Practice notes

Management buyouts—tax on performance ratchets

This Practice Note deals with private equity-backed management buyouts (MBOs) and examines the tax issues arising for UK managers on the operation of...

15th Jan

Practice notes