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Clauses For Concern

 
Paul McCarthy Partner and Jan Evans Professional Support Lawyer Allen & Overy look at some changes to the Inland Revenue's guidance on Part 7 IT(EP)A and highlight some continuing concerns
 
While further guidance from the Inland Revenue on the new Part 7 IT(EP)A charges is helpful it has not entirely allayed the concerns of the private equity sector. This article looks at the changes and identifies where concerns persist.
The Former Regime
Managers' equity
 
Where managers acquired shares at the outset they generally paid less for them than other investors without incurring adverse tax consequences. This was because:
 

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