Jurisdiction(s):
United Kingdom

Related legal acts

Key definition

Private equity definition

What does Private equity mean? Private equity describes investment by professional funds in unlisted (unquoted) companies to obtain minority or controlling stakes, financing growth, management buy-outs/ins, recapitalisations or turnarounds, often alongside acquisition debt. The shares acquired are not admitted to trading on a stock exchange, so are less marketable and less liquid than public (quoted) equity. The term is not defined in legislation or case law; it is a market description used consistently across England & Wales, Scotland, Northern Ireland and Ireland. Transactions are privately negotiated and typically documented through investment and shareholders’ agreements, amended articles, preference shares or loan notes, management incentive arrangements (such as...

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

Published by a LexisNexis Tax expert

Practice notes

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...

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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....

Charishma Bhujohory

Macfarlanes

Charishma joined Macfarlanes in January 2018. She previously worked at PwC and has over five years of experience advising businesses and private clients on various VAT matters.Charishma regularly advises on the management of her clients' ongoing VAT affairs as well as on significant one-off transactions such as M&A deals and property transactions. She has extensive experience of working with a variety of clients including multinational organisations, family owned businesses as well as private clients.Charishma has been involved in negotiations with HMRC and liaises with HMRC regularly in respect of clients' VAT affairs.Charishma is a chartered accountant....

Web page updated on 22/05/2026

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