Many of our clients and readers will be familiar with the “loan to participator” rules. These rules apply to loans made by close companies, which in general terms are companies which are controlled by five or fewer participators (or by any number of participators who are also shareholders), to their
UK Tax
UK Government Carried Interest Tax Reforms Consultation Process: No New Conditions, Territorial Limits Clarified
By Stephen Pevsner, Catherine Sear & David M. Ward on
June 2025 – The UK Government has published its response to the consultation on its proposal to change the tax treatment of carried interest, confirming the expected final shape of the new regime which will take effect from April 2026.
The reforms, first announced in October 2024, mark a significant…
BlueCrest – the Court of Appeal considers Condition B of the salaried members rules
By Charlotte Ahamed, Catherine Sear & Robert E. Gaut on
The Court of Appeal has remitted the case of BlueCrest Capital Management (UK) LLP (BlueCrest) v HMRC back to the First-tier Tribunal (FTT) regarding the application of the UK’s salaried members rules (the Rules) to certain members of BlueCrest, an asset manager engaged in the provision of hedge fund management…
UK Supreme Court confirms no deduction for expenses related to share and asset sale
By Stephen Pevsner & David M. Ward on
On 16 July 2024, the UK Supreme Court (SC) published its judgment in the case of Centrica Overseas Holdings Ltd (COHL) v HMRC. The ruling addresses the issue of whether professional advisory fees incurred in contemplation of a sale of a group company (actually resulting in a sale of…
HMRC updates guidance on UK tax status of non-UK entities and US LLCs post Anson
On 6 December, HMRC updated the section in its International Manual discussing the UK tax characterisation of overseas entities, and of Delaware (and other US) limited liability companies (LLCs) in particular (in INTM180000 and INTM180050).
This part of the International Manual sets out HMRC’s views on whether certain foreign…
BlueCrest – the Upper Tribunal considers the salaried member rules
The Upper Tribunal (UT) has upheld the decision of the First‑tier Tribunal (FTT) regarding the application of the UK’s salaried member rules (the Rules) to certain members of BlueCrest Capital Management (UK) LLP (BlueCrest), an asset manager engaged in the provision of hedge fund management services. We previously reported on…
Upcoming changes to the company share options plan regime
Company share option plans (CSOP) and enterprise management incentives (EMI) are two statutory share option regimes that can be used to incentivise employees in a tax-efficient way. Broadly, where the relevant qualifying criteria have been met, both the CSOP and EMI schemes allow employees to acquire shares in their employer…
Massive U-Turn on Mini Budget
As has been widely reported, a number of the Mini Budget proposals (summarised in our recent Tax Blog) have been scrapped. The new Chancellor of the Exchequer Jeremy Hunt announced these measures claiming that they are estimated to raise £32 billion in taxes every year. More tax rises and…
UK Mini Budget 2022
UK Mini Budget 2022
The Chancellor today unveiled the UK’s 2022 Growth Plan which has been described as being “the biggest package of tax cuts in generations”. We have summarised here the tax changes that we think will be of interest to our client base.
- UK corporation tax: the main
…
HMRC Announces Welcome Changes to the QAHC Regime
By Stephen Pevsner & Philip Gilliland on
On 20 July 2022, the UK government published draft legislation for the Finance Bill 2022-2023.
Of particular interest are amendments to be made to the qualifying asset holding company (QAHC) regime that was introduced from 1 April this year.
The regime is part of the UK government’s attempt to increase…