Simmons & Simmons has responded on those aspects of the HMRC consultation on Reform of UK law in relation to transfer pricing, permanent establishment and Diverted Profits Tax that deal with the UK “investment manager exemption” (the IME) and the related proposed updates to Statement of Practice 1/01 (as amended) (SP1/01).
We are generally supportive of the proposals relating to the IME set out in the consultation. Simmons & Simmons have been involved in discussions with HMRC and HM Treasury in respect of a number of aspects for some time now, and it is clear that feedback that we and others have provided has been taken into account in formulating the proposed approach on updating the IME.
We consider that the proposals as set out in the consultation should maintain (and in some cases improve) the UK’s competitiveness as a location from which to perform alternative investment management services. We do, however, identify below a number of aspects where that competitiveness could in our view be further improved.
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