Split fund meaning

Fund managers and advisers linked to the Local Government Pension Scheme (LGPS) warned that hurried changes could depress investment outcomes, leaving local taxpayers to carry the cost. The government has proposed sweeping reforms to the £400bn LGPS, which is currently split across 86 smaller funds ranging from £300m to £30bn. The plan is to combine these holdings into several much larger megafunds, providing the scale to commit more capital to infrastructure projects. Crucially, the Treasury will set a 5% target for every LGPS administering authority to invest in the local economy...

In this issue: Social housing Children's social care Education Planning Highways Public procurement Governance Local government finance Adult social care Healthcare Licensing Environmental law and climate change Daily and weekly news alerts New and updated content Social housing Social housing To be or not to be… the recurring question of when a homelessness application is an application at all (R (Lyrae) v Somerset Council) In R (Lyrae) v Somerset Council, the High Court endorsed the Court of Appeal’s dicta in Rikha Begum—picked up and used in Minott and Ivory—on how to treat a subsequent ‘fresh’ homelessness approach. The analysis comprises two steps. First (stage one), decide whether the later approach counts as an application at all; the only time the answer is ‘no’ is where it rests on exactly the same factual matrix as the earlier one, ignoring fanciful assertions and insignificant details. Secondly (stage two), if it...

Changizi v Changizi and others [2025] EWHC 735 (Ch) The son argued that inheritance tax (IHT) on the estate ought to be taken from the residuary fund before any division between him and his mother, invoking Re Benham's Will Trusts [1995] STC 21. By contrast, the executors split the residue into exempt and chargeable elements, then met the IHT solely from the taxable portion attributed to the son, relying on the later authority of Re Ratcliffe [1999] STC 262. The High Court (HC) determined that Re Ratcliffe supplies the correct approach, while Re Benham was exceptional and turned on its own facts, setting no general principle. Section 41(b) of the Inheritance Tax Act 1984 prohibits deducting IHT from the exempt share of residue and must therefore be applied. Consequently, the executors’ method—apportioning the residue first and burdening the son’s 1/6 share with the entirety of the IHT—was affirmed. For further IHT guidance, see Practice Notes: Calculating the IHT charge on death and Grossing up and partly exempt...

Subscription and shareholders’ agreement This Practice Note offers guidance for drafters preparing and/or reviewing a subscription and shareholders’ agreement relating to the allotment of shares (and, potentially, loan notes) in a private limited company incorporated in England and Wales by a private equity (or venture capital) fund investor (the investor) within a venture capital (VC) deal, where the structure provides for split exchange and completion, ie conditions must be met before completion of the subscription and shareholders’ agreement. The investment contemplated is into an existing company (the Company), with the current shareholders (typically the business’s founders) keeping the shares they have already been issued in the Company. Set out below are matters to weigh up when drafting and/or reviewing the principal provisions of a subscription and shareholders’ agreement (SSA). Parties The investee company Although the principal parties to the SSA will be the relevant investor and the Company’s founders, the Company will ordinarily be included as a party too, ie the vehicle in which the investor...

An individual is treated as UK domiciled where, although they are domiciled outside the UK under the common law principles outlined in Practice Note: Domicile for UK tax purposes before 6 April 2025 [Archived], a statutory rule nevertheless treats them as domiciled for one or more tax purposes. This Practice Note looks only at the deemed domicile provisions that came into force on 6 April 2017, and insofar as they apply to individuals. For details of the deemed domicile rules in place before that date, see Practice Note: Deemed domicile for tax before 6 April 2017 [Archived]. In contrast to domicile at common law, deemed domicile is not inherited from parent to child. For information on the regime brought in by the Finance Act 2013 allowing a non-UK domiciled spouse or civil partner of a person domiciled in the UK to elect to be treated as UK domiciled for IHT purposes, see Practice Note: IHT issues for mixed domicile spouses and civil partners before 6 April 2025 [Archived]. For guidance...

ARCHIVED : This Practice Note has been archived and is not maintained. It describes the rules for overseas workday relief (OWR) in force before 6 April 2025. Overseas Workday Relief (OWR) provides an exemption from UK income tax for eligible non-domiciled persons who choose the remittance basis, covering unremitted 'general earnings' from employment attributable to duties carried out abroad in the relevant tax year. Following the government’s reforms to the tax treatment of non-domiciled individuals in Finance (No 2) Act 2017, many who had formerly been treated as non-domiciled under UK rules are now treated as UK domiciled for all tax purposes; consequently the remittance basis and OWR are no longer accessible to them under the amended UK tax rules in force. Consult Practice Note: Deemed domicile for tax from 6 April 2017. Before 6 April 2013, a comparable facility to OWR existed on a non-statutory footing under HMRC statement of practice 1/09 (SP 1/09) for individuals resident in the UK only briefly, who were considered...