Our annual briefing highlighting the key 2020 legal developments which impact the funds' industry and previews what can be expected in 2021.
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UK VAT rules change so that the input tax associated with most VAT exempt supplies of financial services (but not fund management) to the EU can be recovered
Prohibition for collective investment schemes comes into force
Start of the "30 day" window for making the first reports under the new DAC6 regime
Issuers may voluntarily file their financial reports for financial years starting on or after 1 January 2021 in European Single Electronic Format
ESMA guidelines on performance fees in UCITS and certain types of AIFs come into effect
Early 2021
Lord Hill to report to HM Treasury on his UK Listings Review following the 2020 Call for Evidence
Early 2021
HM Treasury intends to consult on the proposed power to block listings on national security grounds
Early 2021
FCA intends to consult on proposed new disclosure rules for asset managers, and BEIS intends to consult on proposals to require UK registered companies to make disclosures in their strategic reports which are aligned to the Taskforce on Climate-related Financial Disclosures' recommendations.
Early 2021
FCA proposed notice periods for authorised open-ended property funds to address liquidity mismatch forecast to come into effect 'as soon as possible' in 2021
FCA expects to upgrade the National Storage Mechanism to accept European Single Electronic Format
The Institutional Shareholder Services' updated UK proxy guidelines will apply
By this date, each EU member state had to have decided whether it wants to apply the rule for detached workers set out in the EU/UK protocol on social security coordination
The European Commission consultation on a possible sustainable corporate governance initiative closes
Feedback due for ESMA Consultation Paper on guidelines for funds' marketing communications
Consultation closes on new UK tax privileged regime for asset holding companies in alternative fund structures
Budget to be held – possibly including revenue raising measures as a result of the Government's Covid-19 related spending
Majority of the Sustainable Finance Disclosure Regulations obligations apply: sustainability-related disclosures on the website for in-scope entities and relevant pre-contractual information for products in market
Government's relaxation of company meeting requirements (relating to virtual company meetings and flexibility in holding AGMs) due to expire
Deadline for asset managers wishing to be included on the first list of signatories to the UK Stewardship Code 2020 to apply to the FRC
April 2021
Introduction, with retrospective effect to 6 April 2019, of 10% holdings threshold before the non-resident CGT rules apply in relation to certain disposals involving non-resident funds and insurance companies
April 2021
New off-payroll working rules come into force
Q1 2021
The FCA will adopt a new DTR 5 notification protocol. Instead of emailing TR-1 forms to the FCA, investors will need to complete an electronic TR-1 form which will be sent via an online portal.
Mid 2021
Target time for consensus solution to be reached on OECD's Pillars One and Two tax proposals
During 2021
The European Commission will use the technical advice from the ESMA MAR review to inform its own report on MAR
During 2021
Government intends that the new beneficial ownership register of overseas entities that own UK property will go live
During 2021
HM Treasury to launch second consultation of its Future Regulatory Framework review
April 2021
New off-payroll working rules come into force
Q3 2021
The European Commission aims to publish legislative proposal following review of the ELTIF regime
August 2021
Delegated acts on four remaining environmental objectives to be adopted & Commission to publish a report on extension of the Taxonomy Regulation's scope
