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  31/10/2024

  United Kingdom

  Autumn Budget 2024 - carried interest reform

  In line with its election manifesto the new Labour government will amend the tax treatment of carried interest.From 6 April 2025 until 5 April 2026 there will be an interim increase in the special capital gains tax (“CGT”) rate for carry from 28% to 32%.From 6 April 2026 carried interest will be taxed under the income tax regime and also subject to national insurance contributions (“NICs”).  Where a carried interest meets certain qualifying criteria a 72.5% multiplier will apply lowering the effective additional rate of income tax from 45% to an effective rate of 32.625%...

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  30/10/2024

  United Kingdom

  Autumn Budget 2024 – key tax announcements

  The 2024 Autumn Budget has been one of the most anticipated fiscal events in recent years. Not only is it a post-election Budget – the Labour Party’s first Budget in almost fifteen years – but the length of the period that has elapsed since the election, the Government’s discovery of a £22bn “black hole” in the public finances, and the broad commitments contained in Labour’s manifesto have all contributed to a lengthy period of intense speculation.Recent confirmation from the Chancellor that tax increases were a certainty, combined with the Government’s...

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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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