A regular briefing for the alternative asset management industry. 

Since 6 April 2026, the UK has had a new regime under which all carried interest is taxed as trading income, regardless of the underlying nature of the return. As it is trading income, the starting position is that it is taxed at rates of up to 47% (45% income tax plus 2% national insurance contributions). However, provided the carried interest is "qualifying", a bespoke effective rate of around 34.1% applies.

Geopolitical pressures, technological disruption and shifting energy markets are reshaping what it means to transition to a more sustainable economy. This edition examines how three sectors, energy, defence and digital, are navigating the transition and reviews the regulatory and financial framework that will determine whether the transition succeeds.

The London Stock Exchange ("LSE") has just published a consultation paper, AIM Notice 62 (the "Consultation Paper"), setting out its reforms to the AIM Rules for Companies (the "AIM Rules").

The UK Government has announced that the implementation date for the UK's new subscription contracts regime has been pushed back to "Spring 2027". Whilst this gives businesses more time to prepare, there is a great deal to consider – and as we explain below, the sooner you start that process, the better.

In this edition, we look at infrastructure and energy measures in the King's Speech, how the UK is proposing to decouple gas and electricity prices, the latest state of play on data centres and the impact of conflict in the Middle East.  We also discuss whether pre-development costs should get preferential tax treatment and VAT on electric vehicle charging, together with a range of other regulatory issues affecting the infrastructure and energy sectors. 

HMRC has published the final version of its updated guidance on the application of the UK's investment manager exemption (IME). The IME is important because it helps prevent domestic managers constituting a UK taxable presence of their non-resident clients. As well as reflecting changes made to the legislation underpinning the IME, the final guidance contains important clarifications in relation to how HMRC will apply the exemption in practice.