Mark Stapleton
Partner | London
Mark Stapleton

Mark Stapleton advises on UK and international direct and indirect taxation issues. He has extensive experience in relation to advising offshore funds and the investment management sector, particularly global and international private credit/hybrid debt funds and hedge funds. He also has specialist tax experience of providing structuring and tax advice in relation to CLOs. In addition, he advises on acquisitions of public and private companies, real estate acquisitions, securitisations, structured finance and a variety of other banking, financial and corporate transactions.

Mr. Stapleton is experienced in advising on structuring and establishing international holding companies and financing companies used in connection with inward investment transactions, cross-border acquisitions and also corporate migrations.

Mr. Stapleton is a member and past chairman of the taxation committee of the Alternative Investment Management Association, a member of the tax committee of the Alternative Credit Council, a Chartered Tax Adviser and also a member of the International Fiscal Association.

Mr. Stapleton has been recommended as a leader in his field in the independent legal directories The Legal 500 UK and Chambers UK, in PLC Which Lawyer and in Who's Who Legal. He has been ranked continuously in Chambers for 24 years. Clients quoted in Chambers routinely praise Mr. Stapleton for his "creative, thoughtful and helpful" approach, with sources describing him as "a very clear and calm communicator. He's agreeable yet able to challenge proposals that would not be sustainable long term," "technically impressive and patient in both understanding his clients' objectives and making sure that we fully understand, and are comfortable with, the highly intricate tax advice he provides us with," "thoughtful, diligent, timely and very proactive" and "a good communicator."

Sources quoted in The Legal 500 UK state: "Mark Stapleton is a stand-out tax partner in the private funds space" and praise his "stellar responsiveness and quality of thinking", while adding that they "highly recommend him." He is also noted for his "very personable approach and fast response which is very important in high value time sensitive matters." Clients have also stated that "Mark Stapleton understands all the nuances whether the matter relates to the taxation of the investment manager, its staff and partner remuneration schemes or the tax position of its investment funds both onshore and offshore."

  • Swiss Capital in connection with the set up of a Luxembourg fund platform for European institutional investors and various new credit fund sub-funds.
  • Investcorp, a leading global manager of alternative investments, and Tages, a leading European alternative asset management firm, in connection with a 50/50 joint venture and contribution of their subsequent merger of the Absolute Return businesses to create Investcorp-Tages Limited.
  • Phenna Group in connection with tax matters relating to their MBO of the Phenna Group from Academy Association Inc., supported by a debt placement by CVC Credit Partners.
  • Redding Ridge Asset Management advising Apollo-backed Redding Ridge in connection with tax structuring and European risk retention advice related to CLO investment management activity.
  • Chenavari Investment Managers in connection with key tax opinions related to its third European CLO  (Toro European III CLO).
  • Rothschild Credit Management in connection with key tax opinions related to its fourth CLO (Contego IV CLO).
  • Capitalworks Investment Partners in connection with the establishment of a hedge fund management business.
  • Redline Capital Management in connection with tax implications to a restructuring of a Luxembourg fund to create a new innovative carried interest arrangement.
  • Glennmont Asset Management in connection with the establishment of a private credit fund structure investing in debt across Europe and related tax and structuring issues.
  • MetLife Investment Advisors in connection with international tax advice in relation to withholding tax in 15 jurisdictions.
  • Swiss Capital in connection with integrated tax advice on the entire debt fund structuring of its European direct lending platform.
  • Cheyne Capital in connection with the establishment of a new Luxembourg credit fund with various feeder funds.
  • Apollo Global Management in connection with detailed UK tax advice, on the creation of a new, self-managed global asset management business designed to fulfil US and EU risk retention requirements.
  • EnTrustPermal in connection with UK tax advice on the merger of EnTrust and the Permal Group and on its future business structure.
  • Ziarco Group Limited in connection with the sale of the entire issued share capital to Novartis Pharma AG.
  • Petroceltic International plc in connection with UK tax advice for a group reorganization.
  • AlbaCore Capital Limited in connection with the establishment of a high-profile new fund management business and investment fund.
  • City Financial Investment Company Limited in connection with the establishment of a new Cayman Islands hedge fund.
  • Fund Structuring Solutions  – Speaker, Private Funds Roundtable Series 2023 – Session One (February 2023)
  • The Latest Structuring and Tax Trends Relating to Private Funds – Speaker, Private Funds Legal Retreat 2022 (September 2022)
  • International credit fund structuring using QAHCs and a comparison with Luxembourg downstream structuring – Speaker, AIMA Fund Manager Briefing (June 2022)
  • Common Reporting Standards  Speaker, SS&C (April 2016)
  • The UK funds review: falling short of the goal? - Tax Journal (March 2022)
  • Taxation - Co-author, Hedge Funds and the Law (August 2021)
    • The University of Nottingham, LL.B., 1985
    • England and Wales
    • Chartered Institute of Taxation
    • International Fiscal Association
    • Alternative Investment Management Association