Knowledge

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Taxing non-residents on UK property gains: the rules for funds

There is much for funds to be positive about in the latest draft of the rules taxing non-residents on gains from UK land. In particular, the transparency and exemption elections are included in roughly the form expected, and HMRC has clearly listened carefully to concerns raised by the industry.

Drawing on diversity to drive better decisions

The pensions industry is starting to realise the value of diversity and inclusion in pension scheme trustee boards and beyond. This is about more than reflecting the diversity of pension scheme beneficiaries amongst trustee directors: the evidence is clear that diverse groups, which work well together, are better at making good decisions. 

JIBFL: In Practice - Private equity sponsors as lenders

In this In Practice article, the author highlights some of the key challenges posed by a sponsor affiliate being a lender in a club or syndicated loan transaction, and discusses practical approaches to limiting the associated risks for third party lenders.

JIBFL: In Practice - Lending to FCA/PRA regulated businesses

In this In Practice article the authors consider the practical issues faced by practitioners and deal counterparties in structuring and executing leveraged buyout transactions where the target company is regulated by the Financial Conduct Authority and/or Prudential Regulation Authority.

Tax Journal: Brexit, Air Berlin and the 1.5% stamp duty charge: reasons to be cheerful

It has been settled HMRC practice for some time now that the 1.5% stamp charge set out in FA 1986 in relation to the issue and transfer of UK shares to clearance services and depositaries was restricted by EU law, such that it should arise only on the transfer of shares which were not integral to the raising of capital for the company in question. 

JIBFL: In Practice - Changes to the legal and regulatory landscape for fund-level derivatives transactions

This article considers how certain alternative investment funds (currently those managed by a manager authorised under the Alternative Investment Fund Managers Directive and potentially, in future, all EU alternative investment funds) may need to update their legal documentation in order to margin (exchange collateral on) their derivatives transactions. It also touches upon whether alternative structures are available to allow funds to execute their risk management strategies without the need to margin.

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