1-Hour Program

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Overview

May 27, 2015, 10:00 a.m. - 11:00 a.m. (E.D.T.)

The UK tax treatment of distributions to private equity executives will change substantially from 6 April this year, and will affect any investment manager who undertakes some activity in the UK (even if just meeting with a potential investor).  The new rules seek to tax "disguised investment management fees" to UK income tax rather than under the lower tax rates offered by the capital gains tax regime.  The first draft of the rules, published at the close of 2014, was riddled with problems and brought the tax treatment of carry and co-investment returns into question, as well as having an incredibly broad jurisdictional scope.  On 25th March, the government published the Finance Bill 2015, which included an updated text of the rules.  The categories of exemption are now wider than when they were first proposed, and both the co-investment returns and carried interest definitions more closely (although not always exactly) resemble commercial reality.  The rules could affect any fund which conducts activity (however minor) in the UK and will therefore need to be considered by UK based funds as well as non-UK based funds. 

Please join Richard Ward and Ceinwen Rees from the London office of Debevoise & Plimpton LLP as they: 

  • Explore the key elements of these new rules;
  • Explore the scope of these new rules;
  • Discuss the impact the new rules are likely to have for UK-based funds; and
  • Discuss the impact the new rules are likely to have for non-UK based funds.

Credit Details