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Artículos Recientes

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  12/12/2024

  United Kingdom

  UK Tax Disputes Digest (Winter 2024)

  Welcome to the Winter 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 in relation...

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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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  28/10/2024

  United Kingdom

  The Economic Crime and Corporate Transparency Act 2023: Companies House publishes timetable for implementation

  Companies House has published its much awaited plan (Transition Plan) for implementation of some of the key provisions of the Economic Crime and Corporate Transparency Act 2023 (ECCTA) not yet in force. Delivering the Transition Plan still requires significant investment in terms of Companies House systems and processes, as well as Parliamentary time to enact further secondary legislation. As a result, the new provisions are to be implemented in phases with Companies House anticipating that it will take until 2027 to complete.BackgroundThe ECCTA was enacted as part of Government efforts to combat...

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  09/10/2024

  United Kingdom

  Court of Appeal Decision in Financial Conduct Authority v BlueCrest Capital Management: Implications for Regulated Firms

  IntroductionOn 2 October 2024, the Court of Appeal delivered a significant judgment in the case of Financial Conduct Authority v BlueCrest Capital Management (UK) LLP ([2024] EWCA Civ 1125). This decision addresses: (a) the scope of the Financial Conduct Authority's (FCA) powers under the Financial Services and Markets Act 2000 (FSMA) to impose redress requirements on an individual regulated firm; and (b) on the scope of the jurisdiction of the Upper Tribunal. The judgment has far-reaching implications for the regulatory landscape and the operational conduct of firms within the financial services...

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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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