QAHCs and Credit Funds – Update on Regulatory Registration Requirements

Aron Joy — Mon, 25 Sep 2023 14:25:12 +0000

In April 2022, the UK introduced the Qualifying Asset Holding Company (“QAHC”) regime. The regime is intended to entice investment funds, and certain other investors, to establish their holding structures in the UK as opposed to, for example, Luxembourg or Ireland. To this end, a range of tax reliefs are available to companies that qualify for and elect into the regime, such as no withholding tax on interest paid by a QAHC, the ability to use profit participating instruments to offset returns on debt investments and a blanket UK corporation tax exemption for gains on the sale of (most) shares. QAHCs can also be useful, in particular, for funds whose managers are based in the UK who may have difficulty in establishing or demonstrating sufficient substance in an overseas holding company, which may result in issues with local substance requirements in underlying investment jurisdictions or the proposed Anti-Tax Avoidance Directive III, if it is enacted.

Reform to UK VAT treatment of fund management: consultation published

Aron Joy — Fri, 16 Dec 2022 17:06:52 +0000

On 9 December 2022, the UK government launched a consultation setting out its proposed reforms of the UK VAT treatment of fund management. The full consultation can be found here. The consultation is the long awaited follow up to Budget 2020 in which a wide-ranging review of the UK’s funds regime, covering both tax and

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QAHCs and Credit Funds – Update on Regulatory Registration Requirements

Reform to UK VAT treatment of fund management: consultation published