Helen Lethaby reviews recent developments affecting the City, including profit deferral under AIFMD, compensating adjustments, new DOTAS rules and the Ingenious Media case.
Since HMRC’s announcement in May that it would be removing the scope for individual members of partnerships to defer or avoid tax by having their profit shares accrue to an affiliated corporate member there has been concern about the interaction of the new tax rules with the remuneration requirements of the Alternative Investment Fund Managers Directive (AIFMD).
Many private equity and hedge fund managers operating in the UK are constituted as limited liability partnerships (LLPs). Draft guidance from the Financial Conduct Authority (FCA) on compliance with the AIFMD remuneration code (set out in an FCA quarterly consultation paper CP 13/9 issued in September) indicates...
