GT - Offshore funds survey_UK


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Grant Thornton decided to undertake an industry survey and produce a summary document, designed to facilitate discussions of the issues faced in complying with the new Reporting Fund (RF) regime. This survey is designed and intended for individuals responsible for UK tax and compliance of offshore funds marketed to UK investors.

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GT - Offshore funds survey_UK

  1. 1. Offshore funds surveyGrant Thornton UK LLP June 2012
  2. 2. ContentsThe research was conducted through acombination of telephone interviews andan on-line survey. Respondent anonymity has beenmaintained to ensure that no comments,views or dates can be attributed to anindividual or organisation. This full report will be received by allthose asked to participate in the survey.This will enable them to compare theirown responses with those of other funds,managers and organisations. Contents 2 Contents 3 Introduction 4 Background 5 Summary of survey findings The Survey 6-11 Observations 12 Practical issues – Applications 13-19 Practical issues – Reporting 20-23 Summary thoughts 24 Financial Services Tax/Contacts2 Offshore Funds Survey
  3. 3. IntroductionIntended audience income profits, albeit that losses remain The comments that we receivedThis survey is designed and intended as capital losses. confirmed that these issues which ourfor individuals responsible for UK clients face are also concerns for the widertax and compliance of offshore funds Implementation offshore fund industry. The remainder ofmarketed to UK investors. A level of As with any new and complex regime, this document details the responses to theknowledge of the existing and previous and as confirmed by the results of this questions we asked and also allows for atax rules relating to offshore funds is survey, teething problems along the number of conclusions to be drawn.assumed, but where specific or detailed way cannot be avoided. The original RF We would like to thank all participantstechnical points are referred to further regulations and accompanying guidance who took part in this survey, withoutexplanation is provided. were released after a two year long whose input this survey would not have consultation, and have subsequently been been possible.The new regime updated four times, the most significant We hope you find this survey ofThe new Reporting Fund (RF) regime of which was less than a year ago in May interest and would be pleased to discusscame into effect on 1 December 2009. It 2011. It seems likely that this will not be further with interested parties.replaces and is intended to simplify the the last as more funds seek to join theprevious UK Distributor Status (UKDS) new regime and raise new questions on Grant Thornton UK LLPrules applicable to offshore funds. issues that have not been addressed in the Financial Services Tax Team The purpose of the new regime from existing legislation or guidance. June 2012a tax perspective remains as before, i.e. The transitional provisions within theto prevent conversion of income into regulations allowed for distributing fundscapital gains by the rolling up of income to delay entry into the new regime foroffshore in a low tax environment and one further accounting period followingthen realising this in capital form. the accounting period containing 1 With the current differential between December 2009. Other funds, particularlythe UK capital gains and income tax rates, those which in the past have had tothis is one of the ways HM Revenue & operate reinvestment mechanics or whichCustoms (HMRC) seeks to prevent the had holdings in other offshore funds,avoidance of tax by UK taxpayers. welcomed the ability to enter into the Funds which choose to be part of regime at an earlier stage.the RF regime are required to notify With this in mind, and with theinvestors of income, as calculated under first annual reporting cycle now eitherthe regulations, for an accounting period. complete or currently in progress,UK taxpaying investors must then report Grant Thornton decided to undertakeand pay tax on their share of this income an industry survey and produce aregardless of actual distributions received. summary document, designed toActual distributions are not subject to facilitate discussions of the issues faced infurther tax to the extent they do not complying with the new rules.exceed reported income allocations. The questions asked in this survey Investors realising investments in cover a range of specific areas andreporting funds may treat any gains tried to focus on the issues where wearising on disposal as capital for tax know a number of our clients and thepurposes. Profits made on the disposal of wider industry have had comments andnon-reporting offshore funds are taxed as concerns. Offshore Funds Survey 3
  4. 4. BackgroundA total of 50 selected A wide spectrum of asset classes is It was initially estimated that the represented by the survey participants. survey conversation would take 20offshore fund providers Some respondents represent small funds, minutes, but it was found that in aand administrators were some are very large, multi-fund managers number of cases people preferred tocontacted to participate in and some are from the middle ground. complete the survey electronically. In addition, a number of offshore fund Where conversations did take place thethis survey. administrators were contacted to gather discussion took nearer three quarters of their views. an hour, with the longest lasting an hour Each participant was informed of the and a half. This is clearly indicative of the objectives of the research survey and richness of the responses and the extent the survey questionnaire. The survey of the consideration given to compliance questionnaire contained 23 specific with the regime. The time commitment questions which were grouped under from all involved in this process is very four headings: much appreciated. Discussions took place with Chief • Observations Financial Officers, Chief Operating • Practical issues – Applications Officers, Product Managers and others • Practical issues – Reporting closely involved in the offshore funds • Summary thoughts regime. Respondents were forthcoming and candid in their views expressed. Selected anonymised comments are used throughout this document to emphasise a point or to support conclusions reached by Grant Thornton.4 Offshore Funds Survey
  5. 5. Summary of survey findingsThe original aim of the Simplification In line with expectations, 62% Perhaps unsurprisingly, only 22% of of respondents are using a websiteregulations was to remove respondents think that the new RF as a means of reporting to investors.impediments from the regime is simpler than the previous However, there is concern thatUK tax regime for multi- UKDS regime. That said, for the information is not reaching the majority of people we have spoken to underlying investor, especially wheretiered fund structures, by who have now completed their first year nominee accounts are used or wheresimplifying the operation of reporting, the process appears to have investors do not have access to theof the offshore funds tax run smoothly. internet.regime and providing more Income distribution Equalisationcertainty to UK investors When asked whether or not having to Although only 23% of respondentsand funds. Although the distribute income has influenced the have had difficulties with the operationremoval of the 5% test decision to join the regime, only 41% of equalisation, most respondents of respondents felt that it had. However, highlighted equalisation as being anfor investment in other of those that felt that it had not, a added complexity for which theynon-qualifying offshore number acknowledged the ability now would like to see further guidance fromfunds goes a long way to for accumulation funds to apply for RF HMRC. Surprisingly, given the last man status as being a welcome development, standing issue, only 22% of respondentsachieving this aim, it is potentially enabling some hedge fund have changed their approach toquestionable whether the promoters to now market to the UK equalisation.requirements of the RF without adverse UK tax consequences for investors.regime are simpler thanthose of the UKDS rules. Administration costs 52% of respondents have seen administration costs increase, with the operation of equalisation and increased reporting duties being the main reason behind these increases. Reporting The majority, 70%, of respondents would like to see a pro-forma template introduced to allow a standardised form for reporting. It is believed that this would provide consistency amongst reports helping to improve investor understanding. Worryingly, but perhaps unsurprisingly, only 19% of respondents feel that investors have a good understanding of the information they are provided with. Offshore Funds Survey 5
  6. 6. ObservationsQ. The new definition of an offshore fund Fig 1: New definition of an offshore fundhas resulted in many more funds comingwithin the new regime. Do you have funds Yeswhich fell outside the old definition but 17%now come within the new definition ofan offshore fund, and if so, how has thisimpacted your business? Not applicable 83%Grant Thornton comment:A new tax definition of an offshore fund came into effect on 0 20 40 60 80 1001 December 2009, potentially resulting in more funds cominginto the regime for the first time and therefore having toconsider the impact of the regulations. Most respondents (83%) felt that this had little impact ontheir business. The new definition of an offshore fund provides a newcharacteristics driven definition of a ‘mutual fund’ (S.355& S.356 TIOPA 2010). In the run up to the introduction ofthe new rules it had perhaps been anticipated that a numberof funds previously excluded from the old definition ofan offshore fund would be caught by the new rules. Theresponse to the question indicates that this is not necessarilythe case. As an aside (although untested by this survey) it would “We now have to prepare RFperhaps be interesting to assess how many funds and calculations for funds thatmanagers outside of the old UKDS regime have undertakena review to assess the applicability of the RF regime across previously did not require it”their full range of products. For those answering positively, the inclusion now of someclosed ended funds has created additional work.6 Offshore Funds Survey
  7. 7. Q. The new RF regime facilitates funds not Fig 2: Income distributionhaving to distribute their income. Has thisinfluenced your decision for funds to join Yesthe new regime? 41%Grant Thornton comment:The new rules makes RF status more accessible to funds which Nohad previously been unable or unwilling to satisfy the UKDS 59%requirements. A significant number of respondents considered theintroduction of the new rules as a reason to bring in funds 0 10 20 30 40 50 60which had previously been excluded. This is supported by what is known about the widermarket. Since the inception of the new regime HMRC’s datashows that there has been an approximate 60% increase in thenumber of reporting funds registered compared to the numberof funds registered for UKDS. A number of funds have takenthe opportunity to launch new share classes while the removalof the 5% test has allowed more fund of fund structures toenter the regime. In terms of respondents answering no to this question, anumber cited the potential for ‘dry tax charges’ (investorsbeing assessed to tax on a reported income figure and nothaving the associated distribution to pay the tax) as a reasonfor not bringing more products within the scope of the new “Clients are taking therules. The point made by respondents is very valid where opportunity not to distributeinvestment strategy gives rise to significant income streams.However, where capital growth is the main investment as a way of entering thedriver, with only minimal income arising, it seems likely thatfunds in this position will have chosen to accept a degree of regime, and are nowadministrative work in return for the perceived benefit RFstatus brings. This perhaps indicates one of the reasons why marketing heavily in the UK”the take up of the new regime has been so high. Offshore Funds Survey 7
  8. 8. ObservationsFig 3: Retrospective UK Distributor Status applications Q. Where you have funds that have now decided to join the RF regime but did not previously have UKDS, despite being classified as offshore funds, have you considered retrospective applications for UKDS to potentially help mitigate tax Yes 32% liabilities of UK investors? Not applicable 39% Grant Thornton comment: HMRC has, in the past, allowed retrospective applications for UKDS by funds which have not previously been distributing. This is often seen where funds have little or no income and the extra administration of being part of the regime going forwards No 29% was seen as an acceptable trade-off for the associated investor’s tax benefits. As many readers will be aware, without a specific election by an investor, a fund must have held UKDS or have been part of the RF regime for an investor’s entire period of ownership in order to ensure capital treatment on disposal. With the introduction of the RF regime it had been anticipated that some funds would join the regime and bring older periods into UKDS by making retrospective applications. One particular respondent to the survey confirmed that their organisation has made a number of retrospective applications for long only, non-trading hedge funds. The results support this hypothesis in that 32% of survey respondents have considered making retrospective applications.8 Offshore Funds Survey
  9. 9. Fig 4: Applications for new products5040 Not applicable 41% No30 35% Yes20 24%10 0Q. Has the new regime facilitated making RFapplications for products which you werepreviously unable to obtain UKDS for, andif so, what types of products?Grant Thornton comment:The RF regime has opened up the opportunity for funds andproducts to enter into the regime where before they wereunable to do so due to restrictions imposed under the old “We now have in excessregulations. The removal of the requirement to distribute and the of 500 share classes5% investment restriction are welcome developments, andhas led to both accumulation shares and some hedge funds registered as reportingnow joining the regime. There has also been a significantincrease in the number of fund of fund structures joining the funds”regime, although a number of respondents have experienceddifficulties in collating the necessary information fromunderlying funds. Offshore Funds Survey 9
  10. 10. Observations Fig 5: Marketing assistance60 No 59%504030 Not applicable20 24% Yes 17%10 0Q. To assist with marketing, have youapplied for RF status for funds whichstrictly do not need the status, for example,transparent funds?Grant Thornton comment:Certain fund types, for example some foreign unit trustsand Fonds Commun de Placement, are tax transparent forincome purposes but opaque for capital gains purposes, andare therefore within the new definition of an offshore fund.However, even if the fund chooses to be a non-reporting fund,it is possible for it to still be excluded from potential offshoreincome gains treatment provided they meet certain conditions.As such, there may be no advantage to these funds being in theregime, although some providers have nevertheless sought toapply for RF status in respect of these funds. “We have applied for good non-reporting status for a Comments from some respondents indicate that themarketability of new products is improved if membership of number of funds”the RF regime can be shown even if it is perhaps not needed.This could well be driven by less sophisticated investors orthose with strict investment due diligence checklists.10 Offshore Funds Survey
  11. 11. Fig 6: Administration costs Q. Have you seen administration costs60 increase as a result of complying with the new regime?50 Yes 52%40 No Grant Thornton comment: 38%30 Owing to the increased requirements to provide information to both HMRC and investors it was anticipated that20 administrative costs would increase under the new regime. Comments from respondents indicate that the RF regime10 Not applicable is seen as significantly more complex than UKDS. Specific 10% 0 areas mentioned which have added complexity and therefore costs are effective yield calculations, collation of information for fund of funds and equalisation. In addition the number of non-UKDS funds which have now joined the RF regime will have increased overall costs for larger managers and administrators with wide portfolios of products. Offshore Funds Survey 11
  12. 12. Practical issues - ApplicationsFig 7: Application rejected Fig 8: Further information Yes Yes 14% 0% Not applicable No 100% 86%0 20 40 60 80 100 0 20 40 60 80 100Q. If you have had an initial RF application Q. Have you been asked by HMRC forrejected, what were the stated reasons and further information for either the initialthe ultimate outcome? application or the subsequent reports, and if so, what further information was required? Grant Thornton comment: Managers of offshore funds are now able to obtain forward looking certification of a fund as a reporting fund which will continue to apply until the fund chooses to leave or is removed from the regime. “More information required Respondents commented that HMRC has requested further information to asses initial applications in limited on derivatives and series circumstances, these being where derivatives were being used share classes” and series of share classes being operated. However, in our sample no legitimate applications had actually been refused by HMRC.12 Offshore Funds Survey
  13. 13. Practical issues - ReportingFig 9: Reportable income calculations and reports Fig 10: Pro-forma template Yes 70% Yes 81% No 22% No 19% Not sure 8%0 20 40 60 80 100 0 10 20 30 40 50 60 70 80Q. Have reportable income calculations and Q. Would you like to see a pro-formareports for investors now been prepared for template to allow a standardised form foryour funds? reporting?Grant Thornton comment: Grant Thornton comment:The new rules came into effect on 1 December 2009, meaning The issue of a standardised form of reporting has beenthat the majority of funds have now prepared, or are in the raised with HMRC, who has stated that it has no objectionprocess of preparing their first reportable income calculations. in principle. However, HMRC is also wary of being too However, there are still some funds that were already prescriptive and suggest that an industry-led tool solutioncertified under the UKDS regime which have elected to would seem appropriate.use the transitional provisions to continue to be certified as Respondents to the survey were very much in favour ofdistributing funds for as long as possible. The reason cited for standardised reporting, however the complexity and varietydelaying entry into the new regime is the perception that the of offshore funds would require an extremely sophisticatedUKDS regime is simpler. The requirement to report 100% of ‘one size fits all’ type reporting programme. Respondentsincome rather than 85% has also been a factor. acknowledged this, and a number stated that although they liked the idea in principle, they could see how in practice this would not be easy to implement. “Difficult to implement with different options for equalisation” Offshore Funds Survey 13
  14. 14. Practical issues - ReportingFig 11: Format of report Q. In what format are you making your report to investors available? Other Grant Thornton comment: 7% Reporting funds are required to make a report available Individual email to investor to each investor who is resident in the UK (or which is a 12% reporting fund) within six months of the end of the reporting period. Clearly, the majority of respondents favour the Individual letter dissemination of information via the internet given to investor 19% the saving in cost and administration this represents. Website 62% Smaller organisations may tend to use a variety of other communication methods suited to the needs of their investors. Whilst the internet was clearly the method of choice for the majority of those we spoke to, a number of respondents expressed concern as to whether the relevant information was ending up in the hands of the underlying investor, especially where nominee accounts were being operated. Although HMRC is sympathetic to the industry’s concerns, it has expressed the view that to the extent that the fund is aware that the method of delivery does not achieve the required outcome, then it is the fund’s responsibility to consider whether the information should be supplied in a different format. “My concern is what happens to those without internet access”14 Offshore Funds Survey
  15. 15. Q. Do you feel that investors have a goodFig 12: Investor understanding understanding of what the information50 Not sure means and what they are required to do 50% with it?4030 No 31% Grant Thornton comment:20 Reports to investors must inform investors of the amount Yes actually distributed, the excess of the amount of the 19%10 reportable income over the amount actually distributed, and where applicable, the amount of equalisation per unit. There is concern that non-professional investors will not fully 0 understand the implications of the reports. Clearly, the fact that only 19% of respondents felt that their investors actually understood the information that they were being provided with, suggests that managers could potentially be doing more to educate their investors on what the information means. Funds who tried to address this at the outset, by educating their professional intermediaries as to the implication of the new rules, now feel that this has been particularly beneficial. However, there is still an overriding concern that there is a gap between the sophisticated and less sophisticated investor. Offshore Funds Survey 15
  16. 16. Practical issues - Reporting Fig 13: Equalisation No equalisation 31% Equalisation “I don’t believe you should 19% be allowed to operate Full equalisation 27% without equalisation. It should be mandatory” Income adjustments on basis of reported income 4% Income adjustments on basis of accounting income 0% Different funds using different methods 19%0 5 10 15 20 25 30 35Q. Are you operating equalisation, and if so,what method?16 Offshore Funds Survey
  17. 17. “Addressing the ‘last man standing’ issue”Fig 14: Equalisation difficulties Fig 15: Approach to equalisation Yes 23% Yes 22% No 46% No Not applicable 78% 31%0 10 20 30 40 50 0 10 20 30 40 50 60 70 80Q. Are you aware of any difficulties that Q. Have you changed your approach tohave arisen in the operation of equalisation equalisation since the introduction of theor in doing the income adjustments? RF regime, and if so, why? Grant Thornton comment: The new regulations give a fund five options regarding the operation of equalisation. The results show that there does not appear to be one preferred method, with different funds choosing different methods. “A practical / pragmatic The overriding reason behind these different methods being solution was agreed with adopted was the fact that some funds are operationally able to operate equalisation while others are not currently able HMRC” to do so. Our observation of responses indicates that certain jurisdictions are more accustomed to operating equalisation than others, and have been doing so for a number of years. A number of funds and administrators have encountered various issues ranging from operational difficulties to problems with accounting under overseas GAAPs. Hedge funds also have to deal with performance fee equalisation to add to the complexities. Although not necessarily reflected in the results, in our experience the need to address the ‘last man standing’ issue has led to more income generating funds operating equalisation under the new RF regime. In addition, improved administration systems now allow equalisation to be operated where it wasn’t before due to operational constraints. Offshore Funds Survey 17
  18. 18. Practical issues - Reporting Fig 16: Split between share classes Fig 17: Reportable income from offshore funds100 50 Not applicable 48% 80 No 40 85% No 60 30 36% 40 20 Yes Not sure 16% 20 Yes 11% 10 4% 0 0Q. Have your funds had any difficulties Q. If your funds have holdings in otherobtaining underlying information relating to offshore funds, have they experienced anythe split of income/expenses between share issues obtaining the reportable incomeclasses? If so, please explain how you overcame figures from those funds?these difficulties.Grant Thornton comment: Grant Thornton comment:Each share class of an offshore fund is now considered to be an The abolishing of the investment restriction under theoffshore fund in its own right. Although most administrators are previous regime has made it easier for funds of funds tonow able to provide a split of income and expenses across the achieve certification as reporting funds. However, there isdifferent share classes there are still instances where funds are the additional administrative complexity of determininghaving difficulties obtaining the relevant information. In these the relevant income to be recorded where funds of fundsinstances, HMRC has stated that it is likely to have no issue in are invested in a wide variety of reporting and non-the income/expenses being allocated across the share class based reporting funds.on the Net Asset Value of the share classes, as long as it producesa reasonable outcome.18 Offshore Funds Survey
  19. 19. Fig 18: Series accounting Yes 4%“Only problem is seriesaccounting costs more” No 15% Not applicable 81% 0 20 40 60 80 100 Q. Where share classes operate various series, is reporting in these instances a problem in practice? What problems do you face in this area? Grant Thornton comment: A large number of funds, particularly in the hedge fund industry, issue units in series. Historically, series tended not to be an issue under the UKDS regime, but with the increase in hedge funds in the RF regime there has been concern about the potential for increased administrative complexity if each series is treated as a separate fund, as is strictly required. HMRC has confirmed that where series are collapsed into one share class at the end of a reporting period only one figure of reportable income is required for that share class, thereby reducing the burden on funds. In other cases, however, separate calculations are currently still required. The high level of not applicable responses probably reflects the fact that although common for hedge funds, series accounting is not so common with the total population of funds. Offshore Funds Survey 19
  20. 20. Summary thoughts Q. Do you believe that the new RF regime is Fig 19: Complexity of regime more or less complicated than the old UKDS Less regime, and can you give reasons why? 22% More Grant Thornton comment: 33% The new regime came into effect on 1 December 2009, and as such the industry is still getting used to the regime. Teething problems are inevitable, but it is hoped that with time the Not sure new regime will be a favourable improvement, removing 45% some of the restrictions imposed under the previous regime and providing more certainty to investors.0 10 20 30 40 50 The one clear issue that people do have is with the operation of equalisation, and the complexities that it brings.“The rules are simply morecomplicated, especially onequalisation”20 Offshore Funds Survey
  21. 21. Fig 20: HMRC guidance Fig 21: Other jurisdictions40 8035 Yes No 70 37% 37% No30 60 69%25 Not sure 50 26%20 4015 30 Not applicable10 20 27% Yes 5 10 4% 0 0Q. Is the HMRC guidance detailed enough? Q. How do the RF rules compare to otherWhat other areas would you like to see jurisdictions where you have to report, forcovered in the guidance? example Germany? Are the UK’s rules more complex?Grant Thornton comment: Grant Thornton comment:The original guidance has recently been updated to As can be seen from the opinions expressed in Figure 21,incorporate the amending regulations that came into place the resounding indicative belief is that the UK’s RF regimeon 27 May 2011. Whilst the guidance is useful in a number of is far less complex than that of Germany, as well as Italy,areas it is still felt that more detail could be given in certain Austria and the US. However, it was also not consideredareas, especially regarding equalisation and the adjustments to be the most straightforward, especially under the newrequired to arrive at reportable income. regulations. HMRC has acknowledged that further updating will berequired. It is early days under the new regime and practicalproblems are still arising that will lead to further guidancebeing published. In the interim, HMRC has indicated that itplans to maintain a Q&A page for issues not covered in thecurrent guidance. Offshore Funds Survey 21
  22. 22. Summary thoughtsFig 22: Standardised approach across Europe Fig 23: Exclude certain funds Yes Yes 52% 27% No No 30% 12% Not sure Not sure 18% 61%0 10 20 30 40 50 60 0 10 20 30 40 50 60 70 80Q. Do you believe a standardised approach Q. Do you believe the definition of anto investor reporting across Europe should offshore fund should be amended to excludebe pursued? If yes, do you have any certain funds which are required by theirthoughts on how this could be achieved? home regulator to distribute all income, for example, certain US funds?Grant Thornton comment: Grant Thornton comment:Although half the respondents believe that it is a good idea Certain funds are required by regulation to distribute all theirto standardise reporting across Europe, most doubted that income to investors, eliminating any risk of them rolling upit could be practically implemented unless fiscal unity is income offshore. For these funds, complying with the UK’sachieved. offshore fund rules is an administrative and costly burden that adds no real value to the fund or to HMRC.22 Offshore Funds Survey
  23. 23. “The investment industry across the whole EC shouldhave its own reporting standard relevant to CollectiveInvestment Schemes” Offshore Funds Survey 23
  24. 24. Grant ThorntonDynamic organisations know they need to apply both reason Our Financial Services Tax teamand instinct to decision-making. At Grant Thornton UK LLP, This survey was conducted by the Financial Services (FS)this is how we advise our clients every day. We combine award- Tax team at Grant Thornton. Our FS Tax team compriseswinning technical expertise with the intuition, insight and dedicated specialists supported in the UK by the widerconfidence gained from our extensive sector experience and a multi-disciplinary Financial Services Group of which thedeeper understanding of our clients. tax team is part. Through empowered client service teams, approachable Our advice to clients is based on experience andpartners and shorter decision-making chains, we provide knowledge of the very specific tax issues facing thea wider point of view and operate in a way that’s as fast industry. We are members of The Association of Investmentand agile as our clients. The real benefit for dynamic Companies (AIC), the Alternative Investment Managementorganisations is more meaningful and forward-looking advice Association (AIMA) and the Investment Managementthat can help to unlock their potential for growth. Association (IMA). We are contributing authors to Tolley’s In the UK, we are led by more than 200 partners and Taxation of Collective Investment, Tolley’s Corporation Taxemploy 4,000 of the profession’s brightest minds, operating and provide thought leadership through regular publicationsfrom 27 offices. We provide assurance, tax and specialist and presentations.advisory services to over 40,000 privately-held businesses, Our team advise clients across the FS sector, and have apublic interest entities and individuals nationwide. particular specialism in asset management. We advise funds, their managers and principals and related businesses on allGlobal strength aspects of UK and international tax compliance and planning.Grant Thornton is one of the world’s leading organisationsof independent assurance, tax and advisory firms. Over Should you wish to discuss any issues raised by this survey or any other tax matters please do not hesitate to contact the authors:31,000 Grant Thornton people, across 100 countries, arefocused on making a difference to clients, colleagues and thecommunities in which we live and work. Dana Ward Anne Stopford Partner Director T +44 (0)20 7728 3316 T +44 (0)20 7865 2285 E E Mark Fielden Tim Russell Director Manager T +44 (0)20 7728 2783 T +44 (0)20 7865 2187 E E© 2012 Grant Thornton UK LLP. All rights reserved.‘Grant Thornton’ means Grant Thornton UK LLP, a limited liability partnership. Grant Thornton is a member firm of Grant Thornton International Ltd (Grant Thornton International). References to ‘Grant Thornton’are to the brand under which the Grant Thornton member firms operate and refer to one or more member firms, as the context requires. Grant Thornton International and the member firms are not a worldwidepartnership. Services are delivered independently by member firms, which are not responsible for the services or activities of one another. Grant Thornton International does not provide services to clients. Thispublication has been prepared only as a guide. No responsibility can be accepted by us for loss occasioned to any person acting or refraining from acting as a result of any material in this