Tax Talks

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Katerina Heal

Katerina Heal is a special tax counsel in the Tax Department and a member of the Private Funds Group based in London.

Katerina advises sponsors and investors on a full range of UK and international tax issues involving private investment funds, including in relation to fund formation and operation, co-investment transactions and transactions in secondary fund interests. Katerina’s practice includes advising on matters involving a variety of funds such as buyout, infrastructure, real estate, debt and fund of funds. She also advises UK and international investors such as pension plans (including US private and governmental plans), sovereign wealth funds, separate accounts and other tax exempt and tax paying investors.  Katerina has a broad experience in advising on formation, operation and reorganisation of hedge funds. Her practice also involves advising  fund managers on the establishment and operation of their own businesses, and on the taxation of carried interest and executive coinvestment arrangements.  Katerina was selected by the International Fiscal Association (IFA) in connection with 2019 annual IFA Congress held in London to be one of the two UK IFA Branch Reporters for the 2019 IFA Congress on the subject of private investment funds. A report on this subject is to be published by IFA in September 2019.

Katerina has significant experience advising clients on a broad range of UK and international taxation in areas that include mergers and acquisitions, general corporate transactions, group reorganisations, asset sales, financing transactions, securitisations, international securities offerings and aviation transactions. This has included providing UK and international tax advice to multinational groups on establishment of their operations in the UK and the EU and a broad range of UK and non-UK tax aspects of such ongoing operations.

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Court of Appeal decides that Jersey companies were UK tax resident

In HMRC v Development Securities, the Court of Appeal (the “CA”) has overruled the Upper Tribunal and agreed with the First-tier Tribunal that the relevant Jersey incorporated subsidiaries of a UK parent were resident in the UK for tax purposes by reason of being centrally managed and controlled in the UK. While of considerable interest, … Continue Reading

UK Budget 2020

The UK Budget took place on 11 March. In its first post-Brexit Budget with substantial spending announcements, the Treasury wants to continue to ensure the UK remains an attractive and competitive place to invest and do business. We have summarized here the most notable tax changes that will be of interest to our corporate and … Continue Reading

Simplification of UK Partnership Tax Reporting for Investment Fund Partnerships

In the Finance Act 2018, the UK Government enacted a number of changes to the information required in partnership returns that raised the concern of undue and impracticable administrative burden being imposed on UK investment fund partnerships. The changes covered a number of areas, including requiring a UK partnership that had partnerships amongst its partners … Continue Reading

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