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  24/09/2024

  United Kingdom

  The taxing question of carried interest

  This article previously appeared in Thomson Reuters Regulatory IntelligenceWhilst it is a political decision as to how carried interest is taxed, there is some confusion in the Treasury’s suggestion in the Call for Evidence “that the current tax regime does not appropriately reflect the economic characteristics of carried interest and the level of risk assumed by fund managers in receipt of it.”In our experience, most carried interest is structured in accordance with paragraph 8 of the Memorandum of Understanding (MOU) between the British Private Equity & Venture Capital Association...

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  09/09/2024

  United Kingdom

  UK Tax Disputes Digest (Summer 2024)

  Welcome to the Summer 2024 edition of our UK Tax Disputes Digest: a high-level summary of key developments in contentious tax over the last few months for heads of tax, finance directors, general counsel and other in-house professionals.As with previous editions, we have seen a continued increase in HMRC activity across various areas. Both individual and corporate taxpayers would be well-advised to check their tax position as soon as possible to prepare for any potential HMRC investigation into their tax affairs.In this edition, we look at just a few of these developments, including the latest...

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  06/03/2024

  United Kingdom

  Spring Budget 2024 – key tax announcements

  Against the backdrop of an election (probably) later this year, the Chancellor was evidently feeling the pressure to make tax announcements that would find favour with the electorate, whilst constrained by the economic environment. Warning that further tax cuts can only be funded by growing the economy and making the state more efficient, the emphasis was on fiscal responsibility and increasing resilience to future shocks. The reduction in employee NICs – matching that in the Autumn Statement - had been so heavily rumoured in the immediate run up to budget day that it was hardly a surprise. ...

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  17/01/2024

  United Kingdom

  Vermilion: A Noble Cause or a Taxing Problem?

  Background In 2006, Vermilion Holdings Ltd (“Vermilion” or “the Company”) carried out a funding exercise as part of which Quest Advantage Limited (“Quest”) was appointed to produce a business plan and financial projections and Dickson Minto was appointed as legal advisor to assist with the fundraising.  Vermilion granted a “supplier option” to each of Quest and 22 Nominees Ltd (Dickson Minto’s nominee) to acquire ordinary shares in the Company in consideration for the services provided by Quest and Dickson Minto. The “supplier...

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  23/11/2023

  United Kingdom

  Autumn Statement 2023 – Key tax announcements

  The Chancellor opened his speech with a statement that, “Our plan for the British economy is working, but the work is not done”.  Consistent, perhaps, with the tone of that message, yesterday’s announcements offered few real surprises, with the headline measures – on NI changes and full expensing – already widely anticipated.A summary of the key announcements follows.Tax measures for individuals (employees & self-employed)National Insurance Contributions (NICs) ratesIn relation to NICs, the Chancellor has announced the following.The main rate of Class 1 National...

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  05/09/2023

  Oman

  The New Oman Social Protection Fund Law - Key Changes

  The Sultanate of Oman as a welfare state has for long operated under the old Public Authority for Social Insurance (PASI) Law (Royal Decree 72/9). Recently however, Oman has enacted the novel Social Protection Fund Law (SPFL) (Royal Decree 52/2023) in an attempt to enhance its social welfare framework by creating a single and unified social protection fund that improves financing and provides a wide range of benefits to workers and their families. This article provides an overview of some of the key aspects of the new law and compares it with its repealed predecessor, by highlighting the key impacts...

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