Arup Sen is counsel in the Private Funds Group in Weil’s London office and focuses on advising managers of private funds, primarily infrastructure, private equity and real estate funds with respect to structuring, formation, marketing, operation and management activities, including M&A deals and restructuring programmes. His practice also includes advising on varied investment arrangements and general regulated financial services activities.
Prior to joining Weil, Arup worked at a leading international law firm as well as at The Financial Conduct Authority.
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In April 2022, the UK introduced the Qualifying Asset Holding Company (“QAHC”) regime. The regime is intended to entice investment funds, and certain other investors, to establish their holding structures in the UK as opposed to, for example, Luxembourg or Ireland. To this end, a range of tax reliefs are available to companies that qualify for and elect into the regime, such as no withholding tax on interest paid by a QAHC, the ability to use profit participating instruments to offset returns on debt investments and a blanket UK corporation tax exemption for gains on the sale of (most) shares. QAHCs can also be useful, in particular, for funds whose managers are based in the UK who may have difficulty in establishing or demonstrating sufficient substance in an overseas holding company, which may result in issues with local substance requirements in underlying investment jurisdictions or the proposed Anti-Tax Avoidance Directive III, if it is enacted.
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