International Alternative Asset Management
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Unfixed establishments: Barclays Services Corporation, fixed establishments, and VAT grouping
The Upper Tribunal (Tax and Chancery Chamber) (UT) has dismissed Barclays' appeal against the decision of the First-tier Tribunal (Tax Chamber) (FTT) upholding HMRC's refusal to allow a US company, Barclays Services Corporation (BSC), a member of Barclays' corporate group, to join Barclay's UK value added tax (VAT) group. The main reason for refusing the application was that the US company's registered branch in the UK was not a 'fixed establishment'.
Travers Smith promotes three new partners
Travers Smith LLP has announced today the promotion of three lawyers to its partnership, with effect from 1 July 2026.
Travers Smith advises Inflexion on acquisition financing for Ranger Fire and Security
Travers Smith LLP has advised Inflexion on the acquisition financing for its majority investment in Ranger Fire and Security.
Travers Smith advises Capital Group on the launch of its first European public-private fund with KKR
Travers Smith has advised Capital Group on the launch of Capital Group KKR Global Multi-Sector+ (the Fund), the first sub-fund of the Luxembourg investment vehicle Capital Group Alternative Investments Funds.
Travers Smith's Sustainability Insights: What can (private markets) investors do about climate change?
A regular briefing for the alternative asset management industry.
The UK's carried interest tax regime
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.
UK government proposes reform of taxation of LLC members
The US LLC is a popular business vehicle, particularly in the private capital sector. However, its current UK tax treatment can give rise to effective double taxation for members who are UK resident individuals.
Travers Smith advises on regulatory aspects of $35 billion capital solution for Broadcom AI XPV Platform
Travers Smith has advised on UK and EU financial regulatory aspects of an initial $35 billion capital solution as part of Broadcom's new AI XPV Platform, led by Apollo-managed funds and affiliates in partnership with Blackstone and leading global banks. The transaction represents the largest private financing ever executed and is designed to enable over 20GW in compute capacity for leading frontier AI labs through 2028.
