Sovereign immunity reform – post-consultation stocktake (gated)
07 October 2022As we noted over the summer, between 4 July and 12 September the UK Government carried out a consultation on proposals to reform sovereign immunity from taxation by removing immunity from trading income and real estate income and gains.
If taken forward, these changes will impact on sovereign wealth funds’ (SWFs') UK tax profile and the optimal choice of holding structures for some of their investments.
Now that the consultation has concluded it is perhaps worth taking stock and examining some of the key issues for private equity investment managers.
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