Private equity funds

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Practice notes
Share sale or asset sale—tax considerationsThe sale of a company's business can be structured as either:•a sale of assets owned by the company (an...
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19th May
Practice notes
VAT—triangulationIP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit transition/implementation period entered into following...
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Produced in partnership with John Fuszard of Sagars Accountants Ltd 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
Key tax consequences of an insolvent liquidationThis Practice Note outlines:•the main corporation tax consequences when a UK incorporated company...
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Produced in partnership with Julia Fox of Deloitte LLP and Anthony Davis 19th May
Practice notes
Amortisation of intangible fixed assetsWhere a company acquires (or otherwise incurs capitalised expenditure upon) an intangible fixed asset that...
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Produced in partnership with Anne Fairpo of Temple Tax Chambers 19th May
Practice notes
Property holding structures—SDLT and VAT treatment of a Jersey Property Unit Trust (JPUT)IP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the...
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19th May
Practice notes
Corporation tax—connected personsThis Practice Note looks at the meaning of connected persons within sections 1122 and 1123 of the Corporation Tax Act...
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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
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
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
Section 198 and 199 elections on transactions involving real estateThis Practice Note describes the law and practice relating to elections under...
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Produced in partnership with Martin Wilson 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
Practice notes
Loan capital exemption from stamp dutyDebt which:•qualifies as loan capital (whether it is short or long-term debt), and•satisfies further conditions...
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19th May
Practice notes
The Budget and Finance Bill processThe Budget is a Parliamentary event at which the Chancellor of the Exchequer makes important announcements relating...
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19th May
Practice notes
Capital reduction demergersThe reasons why a company might carry out a demerger, and the different ways in which a demerger may be structured, are...
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Produced in partnership with Zoe Feller of Bird & Bird 19th May

Most recent Private equity funds content

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
Taxation of international private equity funds—offshore fund structuringIP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit...
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Produced in partnership with Ceinwen Rees and Penny Van den Brande of Macfarlanes LLP 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
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 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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