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From Manifesto to Budget: How might the Labour Government change the way carried interest is taxed?

In the first episode of our series From Manifesto to Budget, Tax Partner Elena Rowlands, and Senior Associates Tom Margesson and Sarah Roman from our Asset Management Tax team provide an overview of the carried interest tax rules and discuss what measures the Government might introduce in the upcoming Autumn Budget 2024 to close what it has termed the "carried interest loophole". 

From Manifesto to Budget: Non-doms: How will Labour Move Forward?

In the second episode of this series, Partner Mahesh Varia, Senior Associate Claire Prentice and Trainee Michelle Soo from our Tax team, discuss the potential reforms to the tax treatment of individuals who are not UK-domiciled ("non-doms") in the upcoming Autumn Budget 2024. They cover the Labour party's election manifesto, updates by the new Labour government since winning the election and what we might expect in the Budget.

From Manifesto to Budget: Capital Gains Tax: what can we expect from the Labour Government?

In the fourth episode of this series, Tax Partner Hannah Manning, Knowledge Counsel Kulsoom Hadi and Trainee Solicitors Josh Channon and Amar Degon discuss the possible reforms to capital gains tax to be announced in the Autumn Budget on 30 October 2024. The team reviews speculation from recent commentary and delves into past budget announcements, as well as discussing comparisons with CGT rates in other countries.

From Manifesto to Budget: Business taxes: what can we expect from the Labour Government?

In the third episode of series, Head of Tax, Russell Warren, Associate Ross McGregor and Trainee Nadia Ashbridge discuss the possible reforms to key business taxes including Corporation Tax, VAT and Employer NICs expected to be announced in the Autumn Budget on 30 October 2024. The team also consider Labour's manifesto pledge promising a Business Taxes Roadmap and what this might mean for businesses in the longer term.

Manchester City v the Premier League

Amidst the disciplinary proceedings referred to an independent commission by the Premier League (the "League") in respect of alleged breaches by Manchester City Football Club ("City") of the League's financial rules, a decision has been made in the separate arbitration proceedings brought by City against the League in relation to its rules concerning Associated Party Transactions (the "APT Rules").

Outsourcing Spotlight - Autumn - Winter 2024

Welcome to the third edition of the Travers Smith Outsourcing Spotlight. In this issue, we look at the impact on outsourcing of the new Labour Government's employment reforms and the Digital Markets, Competition and Consumers Act 2024.  We also discuss a range of other topics including artificial intelligence, smart contracts and a recent Supreme Court decision on force majeure clauses.

Travers Smith launches innovative AI Academy

Travers Smith LLP is delighted to announce the launch of its Artificial Intelligence (AI) Academy, an internal training programme, open to the entire firm. This innovative programme, featuring mandatory modules, will leverage the firm's market leading expertise and innovative approach to AI, embedding a deeper understanding of how AI can be used to enhance client engagement, increase productivity and boost efficiencies. 

Price parity / Most Favoured Nation clauses come before the Court of Justice

Background to the referral

On 19 September, the Court of Justice ("CJEU") handed down its judgment in Booking.com BV and Booking.com (Deutschland) GmbH v 25hours Hotel Company Berlin GmbH and Others. This case made its way to the CJEU as a reference for preliminary ruling from the Amsterdam District Court connected to a private dispute between Booking.com and a number of providers of accommodation services in Germany.

Supreme Court upholds anti-suit injunction in support of a foreign seated arbitration

Introduction

In our Dispute Resolution Yearbook article Anti-suit injunctions for foreign seated arbitrations – a closing door?, we discussed the Court of Appeal's decision in UniCredit -v- RusChemAlliance[1] in which the Court of Appeal granted a final anti-suit injunction (ASI) restraining RusChemAlliance LLA (RCA) from pursuing court proceedings in Russia, in breach of a Paris-seated arbitration agreement. The Court of Appeal's judgment was the first time that the English Courts had ordered, on a contested basis, that England was the proper place to bring a claim for an ASI in respect of a foreign-seated arbitration clause.

HMRC confirms hardline approach for when securities fall within employment tax anti-avoidance regime

HMRC has today updated its guidance on the UK's employment-related securities (ERS) rules which can tax, as employment income, benefits arising to employees from securities deriving from their employment.  For these purposes, directorships count as employment and, broadly, securities derive from employment if the right or opportunity to acquire them is, actually, available by reason of the employee's employment. On top of this factual causation test, there is a long-standing deeming provision which, essentially, says that if a security is made available by a person's employer or a person connected with the employer, it will be an ERS (unless awarded due to domestic, family or personal relationships).  

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