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FORTHCOMING CHANGE relating to the tax treatment of carried interest: After a call for evidence on the taxation of carried interest conducted over summer 2024, the Autumn Budget 2024 formally confirmed plans to bring in a redesigned regime for carried interest from 6 April 2026, positioned within the income tax system and accompanied by tailored provisions to reflect the reward’s distinctive attributes. A consultation then explored possible new qualifying criteria for entry to the regime, and the government published its response in June 2025. Draft legislation setting out the new carried interest rules was released on 21 July 2025, intended for inclusion in Finance Bill 2026. The regime is to apply to carried interest arising on or after 6 April 2026. These measures were reaffirmed at the 26 November 2025 Budget, which also noted that revisions had been made to the draft legislation following stakeholder input. In the meantime, ahead of commencement of the new framework, the capital gains tax rate applicable to carried interest was increased to 32%...
This glossary sets out numerous expressions regularly encountered in the restructuring & insolvency sphere. Words shown in bold within definitions are themselves explained in other entries in this glossary as well. A Article X The MLIJ contains a single provision named Article X, aimed at jurisdictions that have already implemented the MLCBI, like England, or are weighing its adoption. Article X states: ‘Not withstanding any prior interpretation to the contrary, the relief available under [insert a cross-reference to the legislation of this State enacting Article 21 of the UNCITRAL Model Law on Cross-Border Insolvency] includes recognition and enforcement of a judgment’ (see Practice Note: UNCITRAL model law on recognition and enforcement of insolvency-related judgments (MLIJ): Article X). Asset-backed security (ABS) A form of security anchored by asset pools, for example loans, leases, and credit card receivables. Assimilated law From 1 January 2024, ‘retained law’ has been retitled ‘assimilated law’. The body of domestic law originally arising from EU obligations, created by the European...
FORTHCOMING CHANGES to EIS and VCT financial limits and call for evidence on tax support for entrepreneurs: At Budget 2025, the government confirmed a cut to the upfront income tax relief for an individual’s VCT investment from 30% to 20%. The EIS upfront income tax relief remains at 30%. It also set out three updates affecting both the EIS and VCT regimes: Raising the annual fundraising ceilings companies may secure under EIS and VCT from £5m to £10m, and for knowledge‑intensive companies (KICs) from £10m to £20m. Increasing the lifetime company risk finance cap from £12m to £24m, and for KICs from £20m to £40m. Uplifting the gross assets thresholds an investee must not exceed from £15m to £30m before shares are issued, and from £16m to £35m thereafter. These reforms will be legislated in Finance Bill 2026 and will take effect from 6 April 2026. Also at Budget 2025, the government launched a call for evidence (closing date: 28 February...