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Ceinwen Rees

Macfarlanes
Ceinwen is a partner in the Macfarlanes Tax and Structuring group. She advises on a broad range of tax and structuring matters with a particular focus on advising investment fund managers on their fund, house, carry and co-investment structuring. Ceinwen also represents investment management and corporate clients in connection with acquisitions, disposals and financing.

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1 Contributions by Ceinwen Rees

UK private equity acquisitions: cross‑border tax structuring and exit planning—acquisition costs, financing, withholding, investor (non-dom/offshore funds) issues, treaties, anti-hybrid/DPT, Luxembourg, and the QAHC regime
PRACTICE NOTES
UK private equity acquisitions: cross‑border tax structuring and exit planning—acquisition costs, financing, withholding, investor (non-dom/offshore funds) issues, treaties, anti-hybrid/DPT, Luxembourg, and the QAHC regime
FORTHCOMING CHANGE relating to abolition of the non-dom regime and introduction of a residence-based regime: At Spring Budget 2024, the government disclosed plans to scrap the remittance basis and bring in a residence-based system from 6 April 2025. Those electing into the new rules will, subject to conditions, be outside UK tax on overseas income and gains for their first four years of UK tax residence. This applies, where the conditions are met, to foreign income and gains throughout the initial four years in full. See News Analysis: Spring Budget 2024—Private Client analysis—Abolition of ‘non-dom’ regime. This Practice Note explores tax considerations when arranging a private equity buyout with both UK and offshore components. There are numerous motives for interposing offshore vehicles in acquisition structures, even where the target is onshore in the UK. Frequently, the structure is tailored to suit investors; for instance, UK-resident, non-domiciled investors in a UK fund may have sought to rely on the remittance basis in respect of their fund distributions. More broadly, certain offshore arrangements can mitigate double taxation within the acquisition chain and at investor level. Since the UK’s qualifying asset holding company (QAHC) regime took effect in April 2022, some of...
Tax
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