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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.

Important Change to Luxembourg’s Reverse Hybrid Rule

Aron Joy — Tue, 10 Jan 2023 16:43:24 +0000

Background Following the EU Anti Tax Avoidance Directive II (“ATAD II“) coming into force, since 2020 EU Member States have been required to implement into their domestic law a package of “anti-hybrid” laws. The aim of these laws is to counteract tax advantages arising from certain “hybrid” features that may exist in any given structure,

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Autumn 2022 Mini Budget: Tax Update

Aron Joy — Fri, 23 Sep 2022 16:27:26 +0000

On 23 September 2022, Chancellor Kwasi Kwarteng delivered his so-called “Mini Budget” which has been variously described as a “game changer”, a “new approach for a new era” and (perhaps less optimistically) a “gamble on growth”. Critics of the government have been quick to point out that the usual Office of Budget Responsibility forecasts have

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