UK reforms to the permanent establishment rules and the Investment Manager Exemption could reshape the tax treatment for non-resident funds and UK investment managers, write James Anderson and Lorenza De Domenico (Skadden).
On 28 April 2025 the UK government published draft legislative amendments to update the UK’s domestic tax rules on permanent establishments (PE) and modernise the Investment Manager Exemption (IME). These changes follow a 2023 consultation and extensive engagement with industry stakeholders reflecting a recognition that the UK’s existing PE and IME rules – some over 20 years old – have fallen out of step with the realities of the asset management sector.
The legislative amendments
The draft legislation published on 28 April amends the statutory definitions of permanent establishment and agents of independent status to more closely align the UK’s domestic definitions to the drafting of Article 5 of the Model Tax Convention on Income...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
UK reforms to the permanent establishment rules and the Investment Manager Exemption could reshape the tax treatment for non-resident funds and UK investment managers, write James Anderson and Lorenza De Domenico (Skadden).
On 28 April 2025 the UK government published draft legislative amendments to update the UK’s domestic tax rules on permanent establishments (PE) and modernise the Investment Manager Exemption (IME). These changes follow a 2023 consultation and extensive engagement with industry stakeholders reflecting a recognition that the UK’s existing PE and IME rules – some over 20 years old – have fallen out of step with the realities of the asset management sector.
The legislative amendments
The draft legislation published on 28 April amends the statutory definitions of permanent establishment and agents of independent status to more closely align the UK’s domestic definitions to the drafting of Article 5 of the Model Tax Convention on Income...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
.tmb-editorspic.jpg?sfvrsn=c9a7a0cc_1)
