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Pensions & investments
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Pensions & investments
PENSIONS INVESTMENTS
Non-doms post-Budget: where are we now?
Helen McGhee
Lynnette Bober
Helen McGhee and Lynnette Bober (Joseph Hage Aaronson) provide an
overview of the new rules and highlight some key points to watch.
Pillar Two and funds: there is no panacea
Alistair Godwin
Andrew Yeomans
Alistair Godwin and Andrew Yeomans (EY) review three areas of complexity
that present challenges to asset managers.
VAT and management of SIFs: a new world post-Brexit?
Giles Salmond
Giles Salmond (Stewarts) assesses the likely impact of Advocate General
Kokott’s opinion in the Dutch pension fund cases.
The new Reserved Investor Fund: what we know so far
Melville Rodrigues
Naomi Lawton
Melville Rodrigues (Apex Group) and Naomi Lawton (Allen & Overy)
provide an overview of the new regime that offers additional flexibility and
plugs a gap in the UK’s existing fund range.
Tax and the City review for March 2024
Zoe Andrews
Mike Lane
Keighley
on the loan relationship rules,
Clipperton
on purposive construction
and the introduction of the Reserved Investor Fund are among the
developments examined by Mike Lane and Zoe Andrews (Slaughter and May).
The new pension tax changes: a practical guide
Elsa Littlewood
Chris Holmes
Chris Holmes and Elsa Littlewood (BDO) examine the overhaul of the pensions tax rules in the Finance Bill.
What should be done about carried interest?
Heather Self
Most would probably agree that the current rate of tax on carried interest is too low. But whatever solution is adopted, a balance needs to be struck between complexity and ‘fairness’, writes Heather Self (Blick Rothenberg).
PE funds and master holding companies: traps for the unwary
James Shorland
James Shorland (Alvarez and Marsal) explores some of the unintended UK tax consequences of master holdco structures on portfolio companies of private equity funds.
Incentivising fund managers: carried interest v growth shares
Kirsten Hunt
Kitty Swanson
Kitty Swanson and Kirsten Hunt (Mayer Brown) consider some key issues regarding incentivising fund managers in the context of the ongoing debate surrounding carried interest.
The reserved investor fund regime: restricted or unrestricted, that is the question
Martin Shah
Martin Shah (Simmons
& Simmons) reviews the proposed reserved investor fund regime, while
Melville Rodrigues (Apex Group) says why it is needed.
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124
EDITOR'S PICK
RBC: from the island of literal interpretation to the continental shelf
Victoria Hine
,
Kyle Rainsford
1 /7
Cross-border group relief: Lloyds tripped up by the ‘main purpose’ hurdle
Gerald Montagu
2 /7
Helping vulnerable individuals: a guide for tax professionals
Chris Holmes
,
Dawn Register
3 /7
A ‘significant’ change in approach? Reflections on the Court of Appeal’s decision in BlueCrest
David Haworth
,
David Haughey
4 /7
ScottishPower and the limits of von Glehn
Rupert Shiers
,
Suzanne Hill
5 /7
Enhancing UK tax policy: how to stimulate business investment and economic growth
Donald Simpson
6 /7
Buckle up your seatbelts: why 2025 will be a bumpy ride for US tax policy
Donald L Korb
,
Andrew Solomon
7 /7
RBC: from the island of literal interpretation to the continental shelf
Victoria Hine
,
Kyle Rainsford
Cross-border group relief: Lloyds tripped up by the ‘main purpose’ hurdle
Gerald Montagu
Helping vulnerable individuals: a guide for tax professionals
Chris Holmes
,
Dawn Register
A ‘significant’ change in approach? Reflections on the Court of Appeal’s decision in BlueCrest
David Haworth
,
David Haughey
ScottishPower and the limits of von Glehn
Rupert Shiers
,
Suzanne Hill
Enhancing UK tax policy: how to stimulate business investment and economic growth
Donald Simpson
Buckle up your seatbelts: why 2025 will be a bumpy ride for US tax policy
Donald L Korb
,
Andrew Solomon
NEWS
Read all
HMRC manual changes: 11 April 2025
HMRC confirm their view on double remittances
NICs (Secondary Class 1 Contributions) Act 2025 receives royal assent
HMRC Directions for internationally mobile employees
Loan Charge review: call for evidence
CASES
Read all
C Purkiss (as liquidator of Ethos Solutions Ltd) v T Kennedy and others
B Patel v HMRC
Other cases that caught our eye: 11 April 2025
St Patrick’s International College Ltd and others v HMRC
Morgan Lloyd Trustees Ltd v HMRC
IN BRIEF
Read all
Excluded property trusts and 6 April 2025
IR35, staffing companies and the small company threshold
Country-by-country reporting goes public
When is 20% not 20%?
Are multiple trusts still a viable IHT planning strategy?
MOST READ
Read all
HMRC’s whistleblower reward scheme: what we know so far
Private schools VAT challenge
Morgan Lloyd Trustees Ltd v HMRC
FA 2025 review: VAT on private school fees: a lack of clarity
FA 2025 review: The loans to participators regime no more (re)paying your way