The U.K. has historically been a popular home to fund managers, whether they originally hail from the U.K., the U.S. or elsewhere. Unfortunately, the same cannot be said about the U.K. with respect to intermediate investment vehicles for international investment funds (i.e., intermediate holding companies or vehicles that house fund assets). Instead, those intermediate holding structures are predominantly found in other jurisdictions in Europe, including Luxembourg, Ireland and the Netherlands. In a guest article, White & Case attorneys Will Smith and Lily Teh outline the main reason why the U.K. has historically proven to be an unpopular jurisdiction for intermediate holding structures. The article also provides details as to why that might change in the near future, especially in light of an ongoing consultation into the issue by the U.K. government. Finally, the article examines why the change, if it occurs, may have significant long-term benefits for international investment managers. For more from Smith, see “Current Tax Challenges for Funds With European Investments” (Jun. 25, 2020).