Does the UK – Italy Treaty violate European law? Reflection in the light of new tax transparent funds introduction

Marco Guerra, LLM University of Milan; LLM Student, King’s College London
Alin Fouladvand, MSc Risk and Finance, London School of Economics

Introduction

On July 17, 2012, the Finance Bill 2012, amending the Corporation Tax Act 2010, introduced the Tax Transparent Fund (hereinafter, the “TTF”), a new authorised collective investment scheme structure. The aim of the TTF is to attract overseas investment into the United Kingdom and positively reinforce the UK’s reputation as a world-class financial centre. Up to now, several investors have preferred to invest through Common Contractual Funds in Ireland, Funds Common de Placement in Luxemburg or Fundsen Voor Gemene Rekening in Netherlands or, outside of Europe, through exempted limited companies in Cayman Islands.

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