The UK government recently published an unexpected consultation setting out proposals to reform the existing UK sovereign immunity exemption from direct tax. The proposals include significantly restricting the scope as well as changing the eligibility criteria for this exemption.

In this podcast Joshua Critchlow discusses the proposals in the consultation with London tax partners Helen Buchanan and May Smith and London tax associate Charlotte Anderson.

This includes a detailed overview of the key proposals and the rationale for the proposals as well as discussion on which investors will be most impacted by these proposals. It is highlighted that the most significant implications are likely to be for sovereigns investing in UK real estate, including sovereign wealth funds and overseas government pension funds, as well as fund managers that have relied on the sovereign immune status being available for investors