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Tax

Our leading tax, reward and private wealth teams advise clients in the private capital industry on all of their tax and structuring requirements across advisory, transactional and dispute matters

Our range of services

Transactions

We advise and act on credit fund deal structuring, private equity deal structuring, restructurings, continuation funds and investment management M&A.

Fund structuring

We structure the full range of investment funds with a focus on private equity, special situation, real estate and private credit strategies.

Asset holding companies

We advise on all aspects of the UK Qualified Asset Holding Company (QAHC) regime and provide extensive advice on asset holding companies in Luxembourg and elsewhere.

Global carry and co-invest structuring

We design, advise on and implement carried interest, co-investment and levered co-investment schemes for all types of private funds on a global basis.

Operational tax function

Our US tax trained operational tax team assists our private capital clients on the full range of fund tax compliance from onboarding, through tax filings to personal tax compliance.

Group advisory

We work with managers on all aspects of group structuring and reorganisations, from design and implementation through ongoing operation to advising our sponsor clients on stake sales.

Disputes and risk management

We help our clients navigate HMRC and overseas tax authority enquiries, and mitigate tax risk exposure, combining our advisory practice with dedicated tax risk management and tax litigation teams.

Mobility and employment tax

We provide employment tax advice, both for UK and internationally-mobile employees and fund executives, incorporating employment law and specialist remuneration and incentives considerations.

Private wealth

We work with our top-ranked private client team to design and implement practical solutions for individuals in the private capital industry.

Specialist advice

We support our clients with a full range of specialist non-legal services including transfer pricing, tax and business valuations, and technical accounting advisory support.

Featured insights

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QAHC report
QAHC report
QAHC report
QAHC report

Featured report

UK asset holding company regime

This guide explains the UK’s qualifying asset holding company (QAHC) regime, introduced in April 2022, which encourages investment funds to base their holding structures in the UK. It provides an overview of the rules, practical guidance on implementation for private equity and credit funds, and excludes real estate aspects.

Download full report (PDF)

August 2024

Inpatriates and carried interest

While the HM Treasury call for evidence is focused on the design of the future UK carried interest rules, the interaction of those rules with the taxation of inpatriates is equally important. In this article we explain how the UK currently receives an out-sized share of total European carried receipts and outlines that, to maintain that preeminent position in the future, it is critical that the UK can retain private capital executives that are currently inpatriates and continue to attract the next generation of inpatriate talent.

August 2024

Reforming carried interest

Following HM Treasury launching a “call for evidence” on reforming the taxation of carried interest, this article explains the existing UK carried interest regime, looks at comparable regimes across the globe and sets out potential options for reform in the UK.

June 2024

Tax distributions and carry clawback

Questions around tax distributions and carry clawback provisions in LPAs have come up in practice more often in recent months. We have written this Private Capital Solutions briefing to explore these topics in more detail.

Handpicked private capital tax insights from macfarlanes.com

Pillar Two: what investment funds need to know

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Handling HMRC enquiries: tips for success

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Preventing unnecessary VAT leakage in a private capital setting

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Carried interest - treatment for UK and US tax purposes

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Tax pitfalls can arise for Private Equity Executives on the move

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Dealing with identified tax risks in transactions

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Carried interest valuation considerations

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Cross border working: what’s the risk for UK fund managers?

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Private Capital Solutions Tax events

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The 2025 Private Capital Solutions Tax event schedule will be released in early January 2025.

Sign-up to the Private Capital Solutions mailing list to receive event information.

PETF member-only events

If you were a member of PETF you will continue to have access to previous member-only event resources for all of the 99 online PETF events from 2020 to 2024.

Download previous PETF event list (PDF)

Contacts

Damien Crossley

Damien Crossley

Partner, Tax

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James McCredie

James McCredie

Partner, Tax

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Sophie Donnithorne-Tait

Sophie Donnithorne-Tait

Partner, Tax

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Alicia Thomas

Alicia Thomas

Partner, Tax

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Jeremy Moncrieff

Jeremy Moncrieff

Partner, Tax

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Joe Robinson

Joe Robinson

Partner, Tax

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Mark Baldwin

Mark Baldwin

Senior Advisor

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Rhiannon Kinghall Were

Rhiannon Kinghall Were

Head of Tax Policy

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Bezhan Salehy

Bezhan Salehy

Tax Policy Specialist

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