Click below for further background and our policy response.
Carried interest is the share of returns that fund managers receive from successful investments. A separate tax regime applies to carried interest, to reflect its unique characteristics as a type of return that is only made in the long term, and there is a real risk will never be paid at all.
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The salaried member rules determine when LLP members are treated as employees for tax purposes. BVCA engagement aims to ensure the rules reflect commercial reality and do not unintentionally affect private capital structures.
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Pillar Two is a global tax reform introducing a 15% minimum tax on certain large multinationals, with related detailed compliance requirements. The rules have potentially wide-ranging implications for international private capital structures.
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The UK qualifying asset holding company (QAHC) regime provides a competitive framework for asset-holding companies used in private capital structures, offering tax neutrality for eligible investment activities and encouraging more funds to base their operations in the UK.
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FATCA and CRS are international regimes requiring financial institutions to report information about overseas investors to tax authorities. The rules have implications for private capital funds structured as limited partnerships because these are classed as financial institutions for these purposes.
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A series of agreements designed to help BVCA members on specific technical issues.
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