A&M Tax London Asset Managers Briefing Note: Volume 18
1. Autumn Budget
On November 22, 2023, Chancellor Jeremy Hunt presented the UK's Autumn Budget. While there were no major updates impacting asset managers, we've outlined key points below. View a detailed download here.
National Insurance Contributions:
- Main rate cut from 12% to 10% from January 6, 2024.
- Class 2 NICs abolished from April 6, 2024, and Class 4 NICs main rate reduced from 9% to 8% from the same date.
- No changes announced to employer NICs, the NICs thresholds, or the rates for earnings above the upper threshold.
Business Tax:
Full expensing for certain plant and machinery made permanent, reducing the impact of the corporation tax rate rise to 25%. Relevant for portfolio companies.
Pensions:
Government to consult on granting pension savers the right to require new employers to pay contributions into their existing pension, simplifying the pension market.
2. Funding of Co-Investments
In a challenging fundraising environment, investors demand fund managers to invest in the funds they manage. Funding co-investment commitments can be a significant cash outlay. This article provides insights into funding options, emphasizing the importance of considering tax implications. We recommend seeking UK tax advice on both funding co-investment and receiving co-investment returns.
3. HMRC v BlueCrest
This article highlights key takeaways from the Upper Tier Tribunal (UTT) in HMRC v BlueCrest Capital Management (UK) LLP [2023]. The BlueCrest case is the first to examine the salaried members rules in the context of an asset management Limited Liability Partnership (LLP). Learn how A&M can assist you in navigating this case.
