Bezhan Salehy

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Articles

Reforming carried interest

Aug 26, 2024 | lexology.com | Damien Crossley |James McCredie |Sophie Donnithorne-Tait |Alicia Thomas |Joe Robinson |Mark Baldwin | +2 more

Reforming carried interestmacfarlanes.com 2 IntroductionPrivate capital is of significant and growing importance to the UK, both as a source of vital investment for UK projects but also as an industry that is itself a key component of the UK's financial services sector. Currently, London is second only to New York as the world's leading private capital hub.
Pillar Two: What Investment Funds Need To Know

Jul 26, 2024 | mondaq.com | Bezhan Salehy

Pillar Two is an international tax reform initiative that aims to ensure that large multinational groups pay a minimum effective tax rate of 15% on all their profits, on a country-by-country basis. This is to be achieved by countries implementing top-up tax rules – known as the GloBE Rules – under which they will charge parent companies in large multinational enterprise (MNE) groups a top-up tax in respect of the profits of any low-taxed foreign subsidiaries they have.
Policy In Practice: Pre-election 2024 - Tax (Podcast)

Jun 28, 2024 | mondaq.com | David Gauke |Bezhan Salehy

In the latest episode of our pre-election policy in practice podcasts, David Gauke and Bezhan Salehy discuss tax policy with a focus on business taxes. They cover: Labour's plans to raise revenue through targeted revenue measures; business tax strategy; and a focus on economic stability. If you would like more information or want to discuss any of the topics in this podcast, please get in touch with David and Bezhan.
Policy in practice: pre-election 2024 - tax

Jun 27, 2024 | lexology.com | David Gauke |Bezhan Salehy

Click here to listen to the audioIn the latest episode of our pre-election policy in practice podcasts, David Gauke and Bezhan Salehy discuss tax policy with a focus on business taxes. They cover:Labour's plans to raise revenue through targeted revenue measures;business tax strategy; anda focus on economic stability. If you would like more information or want to discuss any of the topics in this podcast, please get in touch with David and Bezhan.
One minute with... Bezhan Salehy

Mar 20, 2024 | taxjournal.com | Bezhan Salehy |Edward Hayes

Home >Articles > One minute with... Bezhan Salehy One minute with... Bezhan Salehy 20 March 2024 My job at Macfarlanes involves a mixture of policy and general tax advisory work. In policy, the Spring Budget has generated more work than I have might have expected a week beforehand! The unexpected announcement of reforms to the non-dom regime is a fundamental restructuring of that part of the tax system.
Tax Pitfalls Can Arise for Private Equity Executives on the Move

Mar 8, 2024 | news.bloombergtax.com | Bezhan Salehy

The private equity industry thrives on international talent: post-pandemic it’s increasingly common to see executives change residence from one European city to another for both professional and personal reasons. Such moves can give rise to a range of tax issues, especially in relation to carried interest. The European countries with major financial centers all tax carried interest, or “carry,” at similar rates, as shown in the table below.
Reforming Transfer Pricing, Permanent Establishments And Diverted Profits Tax – Government Response - Corporate Tax - UK

Jan 25, 2024 | mondaq.com | Rhiannon Kinghall Were |Bezhan Salehy

Following a consultation over the summer of 2023 the Government has considered the responses it received to its proposals to reform transfer pricing, permanent establishment rules and the Diverted Profits Tax (DPT). Broadly, the proposals seek to align the UK rules with international standards and double tax treaties as well as bring clarity and certainty.
Response To Proposals To Reform Transfer Pricing, Permanent Establishments And DPT - Transfer Pricing - UK

Aug 18, 2023 | mondaq.com | Bezhan Salehy

Macfarlanes has responded to the Government consultation to reform transfer pricing, permanent establishments and the Diverted Profits Tax. In our response to the consultation (members-only content) we voiced our broad support for the proposal to align UK legislation more closely with the OECD rules.
Pillar Two: compatibility of the UTPR with double tax treaties

Jul 17, 2023 | macfarlanes.com | Bezhan Salehy |Sarah Ling

The Pillar Two undertaxed profits rule could, in theory, be susceptible to challenge under applicable double tax agreements (for example, under business profits or non-discrimination articles). However, even if theoretically possible, there are practical obstacles to raising such a challenge and it is uncertain how, if a UTPR charge was challenged under the mutual agreement procedure of a DTA, countries’ competent authorities would approach the issue.