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The disguised investment management fees rules revisited

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The disguised investment management fees (DIMF) rules have applied to ‘disguised fees’ arising to investment managers since 6 April 2015. The rules have often been overlooked, falling between the two stools of corporate and personal tax advisers. The impact of the regime is so potentially adverse that many have put their heads in the sand and hoped it will pass over them. As one would expect, HMRC has now commenced enquiries into the application of the DIMF rules for 2015/16 onwards. It is important for advisors to be able to identify clients at risk and to be in a position to deal with the demanding factual and technical aspects of the rules if faced with HMRC enquiries.

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