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Private capital executive remuneration is commonly a mixed bag of returns from a variety of sources. This can make the tax analysis complex, and unless detail is provided to it, hard for HMRC to check.
A regular briefing for the alternative asset management industry.
In February 2024, HMRC controversially amended its published guidance on the salaried member rules to say that, in its view, increases in capital contributions made solely to fall outside the salaried members rules would be ineffective. Following strong concerns and disquiet expressed by many (including those in the private capital industry), HMRC decided to conduct an internal review of those changes.
2025 – Challenges and Opportunities
In its recent judgment in HMRC v BlueCrest Capital Management (UK) LLP, the Court of Appeal has overturned the decisions of the lower tribunals and supported HMRC's narrow interpretation of "significant influence". In doing so, the Court introduced a new focus on the source of a member's influence, holding that the only influence that counts is that derived from legal rights and duties. In addition, the Court appeared to support HMRC's view that the scope of significant influence is limited to strategic influence over the affairs of the LLP generally.
Jonathan Gilmour, Head of our Derivatives & Structured Products Group and member of the Governance Committee of the UK Voluntary Carbon Market (VCM) Forum, answers the team's most frequently asked questions surrounding VCMs and the potential implications for investors.
Since our last briefing, there have been several significant tax developments which affect the real estate sector. The new Labour Government's first Budget included welcome confirmation that it will press on with introducing a new form of investment fund (the RIF) that is expected to be particularly attractive for investment in commercial real estate, and proposals for significant reform to the tax treatment of carried interest.
In this edition, we focus on the infrastructure implications of the new Labour Government's first Budget, including for energy, vehicles, telecoms, housing and major projects. We also look at new initiatives affecting the UK water industry and UK infrastructure investment more generally. Please get in touch if you would like to discuss any of the issues discussed below.
A regular briefing for the alternative asset management industry.
Find the latest news, views and our analysis of all the key announcements.
In line with expectations, a series of Inheritance Tax changes have been announced by the Chancellor. The three new policies announced at the Budget can be summarised as follows:
It should come as no surprise that measures contained in the Budget replace the UK's current tax regime for non-UK domiciled individuals ("non-doms") with a new regime. Before the general election, the previous Conservative government and the Labour party in opposition both committed to introducing this change.
Prior to the Budget, there was widespread speculation that the Chancellor would make sweeping changes to the Capital Gains Tax ("CGT") regime, either by significantly increasing rates or by radically reducing existing reliefs (or both). However, as it turns out, most will likely view the Budget CGT changes as being relatively modest in comparison with what the government might have introduced. It seems unlikely the measures announced today will cause a substantial change in taxpayer behaviour as, crucially, there still remains a significant delta between the highest rates of income tax (45%) and capital gains tax (24%).
From an incentives and remuneration perspective, the measures announced in the Budget were rather piecemeal. With no fundamental changes to tax-advantaged employee plans (we are still waiting for a response to the call for evidence on all-employee plans) other aspects of the Chancellor's statement could nevertheless increase their appeal.
On 8 October 2024, the Investment Association (IA) published its much anticipated "Principles of Remuneration" (Principles) to guide remuneration committees over the 2025 AGM season.
In the fifth episode of this series, Senior Counsel Elissavet Grout, Senior Counsel Joseph Sheldrick and Associate Amy Broderick from our Tax team discuss the current inheritance tax rules and the potential changes that are anticipated in the forthcoming Autumn Budget.