• Service: Tax, Global Indirect Tax, Global Mobility Services, Global Compliance Management Services, International Tax
  • Type: Regulatory update
  • Date: 7/25/2014

United Kingdom - Amended offshore funds regulations affect alternative investments 

July 25: Amendments have been made to the offshore funds regulations that affect alternative investment fund managers operating as a partnership and having partners who elect to allocate their profit share to the alternative investment fund manager under the deferred remuneration provisions.

When a participant holds an investment in an offshore fund that was a non-reporting fund during the "material period," the participant will have an offshore income gain on disposal of the investment. Under the amended regulations:

  • It is confirmed that the "material period" begins from the date the variable remuneration was awarded to the participant, not from when it is vested.
  • When an offshore fund changes from a non-reporting fund to a reporting fund before vesting takes place, a participant cannot make a deemed disposal election to crystallise any offshore income gain up to the date of the change and then have an investment in a reporting fund going forward.

Read a July 2014 report(PDF 882KB) prepared by the KPMG member firm in the United Kingdom: Weekly Tax Matters (25 July 2014)

Other topics discussed in the KPMG report concern:

  • OECD approves 2014 Update to the OECD Model Tax Convention
  • OECD global standard for automatic exchange of tax information
  • Consultation on SDLT for property investment funds
  • Bratt Auto Services Ltd and Bratt Auto Contracts Ltd - First-tier Tribunal
  • Emblaze Mobility Solutions Ltd - First-tier Tribunal
  • Equoland (C-272/13) – CJEU Judgment
  • Government confirms radical pension changes announced at Budget 2014
  • HMRC issue guidance on dual contracts
  • National Insurance Contributions Bill 2014 introduced to Parliament
  • HMRC publish consultation on reducing ATED administrative burden

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