Investment Limited Partnership

As noted in December, Ireland’s long awaited new Investment Limited Partnership regime was reaching the final stages of legislative approval. In an early Christmas present for the Irish funds industry the new Investment Limited Partnership (Amendment) Act 2020, was signed into law by the President on 23^rd December. It is now expected that the legislation will be commenced from 1^st February to coincide with some related changes to the Central Bank’s QIAIF rulebook. Interest in the revised structure is strong and further details are available here.

Brexit – The end of the beginning

December 24^th saw a last minute trade deal between the EU and UK. Unfortunately, the deal contained little to cheer in the financial services sector. All eyes are now on discussions on equivalence with no news expected before March.

With the transition period ending on December 31^st, the UK’s Temporary Permissions (TPR) window has closed. It is still possible to register additional sub-funds of UCITS funds where the umbrella has previously been registered under the TPR. There is no such flexibility for EU AIFs or new UCITS umbrellas which will likely make use of the UK’s private placement regime.

Carne can provide clients with solutions for both EU and UK funds and has also recently launched a UK appointed representative service.

On 26^th January, the UK Treasury launched a call for input on a review of the UK Funds Regime. Input is sought on reforming the taxation and regulation regime in place for UK funds. The UK is also looking at other ways to enhance their $9.9 trillion asset management industry including expanding fund administration hubs outside of the South East, enhancing existing fund structures and creating new long term asset funds.