By: Giles Bavister, Ayesha Gill, and Neil Woodgate
From 6 April 2026, carry will be redefined and taxed in the United Kingdom as deemed UK trade or business income where investment management services (as redefined) are performed in the UK. The relevant draft legislation was published by HMRC in July 2025.
By: Shane Geraghty, Michelle Lloyd, and Sneha Thomas
The Irish Finance Bill 2024 will, with effect from 1 January 2025, create a new participation exemption for foreign dividends. This exemption will bring Ireland into line with the rest of the EU which has a similar exemption. It is specifically designed to benefit Irish-resident companies that receive foreign-source dividends. The development has been broadly welcomed and is particularly noteworthy for the asset management industry and investment funds engaged in cross-border investments.
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