Melville Rodrigues (Apex Group) and Naomi Lawton (Allen & Overy) provide an overview of the new regime that offers additional flexibility and plugs a gap in the UK’s existing fund range.
Keighley on the loan relationship rules, Clipperton on purposive construction and the introduction of the Reserved Investor Fund are among the developments examined by Mike Lane and Zoe Andrews (Slaughter and May).
Most would probably agree that the current rate of tax on carried interest is too low. But whatever solution is adopted, a balance needs to be struck between complexity and ‘fairness’, writes Heather Self (Blick Rothenberg).
James Shorland (Alvarez and Marsal) explores some of the unintended UK tax consequences of master holdco structures on portfolio companies of private equity funds.
Kitty Swanson and Kirsten Hunt (Mayer Brown) consider some key issues regarding incentivising fund managers in the context of the ongoing debate surrounding carried interest.
In the Spring Budget, the chancellor announced significant changes to pensions taxation, not least the abolition of the lifetime allowance. Mike J Haynes (Andersen) identifies the opportunities and the risks in the new regime.