Investissements en capitaux, gestion d'actifs et fonds

eAlerts Récentes

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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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  25/11/2024

  International

  Pre-hedging: IOSCO publishes delayed Consultation Report

  On 21 November 2024, the International Organization of Securities Commissions (“IOSCO”) published a consultation paper in response to concerns about the appropriateness of pre-hedging practices raised by various market participants, standard setters and national and supra-national authorities. In short, pre-hedging is the well-established practice by which dealers in certain markets look to hedge their exposure to anticipated client orders for a number of reasons, including to enable the dealer to take on the risk of the client order once confirmed, and to offer a competitive price.BackgroundEuropean...

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  21/11/2024

  United Kingdom

  Critical third parties: final policy and rules demonstrate a welcome cooperation between regulators and industry

  The new critical third parties (CTPs) regime comes into force from 1 January, 2025 and will be hugely significant for designated CTPs to the UK financial sector.The policy statement issued jointly by the Financial Conduct Authority (FCA), Prudential Regulation Authority (PRA) and Bank of England (PS24/16/PS16/24) provides feedback to responses received to the consultation paper earlier this year.Overall, the finalised rules have focused this expansion of the regulatory perimeter on the most systemic risks to the financial industry presented by CTPs.ClarificationThe new rules offer some helpful...

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  18/11/2024

  UAE

  New Guide on Tax Residence and Tax Residency Certificates Application Procedure – Juridical Persons

  On 18 October 2024, the Federal Tax Authority (FTA) released a Tax Procedures Guide TPGTR1 (the “Guide”) on Tax Residents and Tax Residency Certificates (“TRC”).The Guide outlines the criteria for determining when individuals or legal entities qualify as Resident Persons under the UAE Corporate Tax Law (the “CTL”) (as defined by Article 11(3) of the CTL), Tax Residents under UAE domestic law or Tax Residents under Double Taxation Agreements (“DTAs”) (as defined by Articles 3 and 4 of Cabinet Decision No. 85 of 2022).Tax residency rules in the UAEResident...

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  08/11/2024

  United Kingdom

  Levelling the playing field in investment research: introducing payment optionality for pooled funds (FCA CP24/11)

  On 5 November 2024, the Financial Conduct Authority (“FCA”) published a consultation paper (CP24/21) on investment research payment optionality for fund managers. The FCA is proposing to take forward the recommendations of the Investment Research Review (“IRR”) and feedback to its earlier consultation for MiFID investment firms, by extending payment optionality for investment research to fund managers and pooled funds (including UCITS and AIFs).The proposals would allow fund managers to purchase investment research by making joint payments (i.e. by paying for bundled investment...

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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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