Fund tax advice

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Whether you are looking to establish a new fund, raise new investment for an existing fund or ensure compliance and regulatory requirements are met we have all the expertise you need to structure your fund in a tax efficient manner.

In addition, our dedicated experts advise on designing the optimal deal structure and how to effect transactions. The team provide solutions to support a broad range of transactions, including acquisitions, financial restructurings, bolt on acquisitions and exit planning.

Our experts can help you navigate the maze of tax issues which inevitably arise when it comes to considering the way in which the fund will make investments in terms of both the tax position of your investors as well as the impact on your carried interest/co-investment schemes for executives and the complex reporting requirements this drives.

The team starts by looking closely at the specific transaction objectives to be achieved. These are balanced with the relevant accounting, tax, regulatory and commercial considerations to provide you with the optimal deal structure. The team will also continue to provide ongoing support in relation to reporting and compliance for both the house and executives.

We have advised on over 18 Fund raisings, comprising £120bn+ in the last 24 months

Our clients cover a broad range of asset classes: PE, Real Estate, Infrastructure and Credit

Our offerings

Fund structuring

  • Advising on the legal form and jurisdiction of the fund vehicle/s.
  • German/US specific investor requirements in Private Equity and associated structuring advice.
  • Impact of the location of; fund manager/advisor and the impact on PE houses and key executives.
  • Carried interest structuring considerations.
  • Co-investment structures for cross boarder teams/globally located teams.
  • PE VAT implications.
  • Incentivisation of key executives

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Fund Reporting

  • Provision of carry and coinvest tax reporting information for PE execs including UK, US and Germany.
  • Provision of tax reporting for investors including UK, US, Germany.
  • Preparation of tax returns and other filings for: fund partnerships, GP entities, carried interest vehicles, co-invest vehicles and other manager/advisor entities.
  • Review of Fund investments, reorganisations and exits to determine the tax treatment for investors.
  • Input on fund set up to consider reporting obligations, side letter commitments and operation of LPA’s.

 

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Executive Tax Services

  • Tax advice for private equity executives and their families.
  • Personal tax compliance services (UK and US) including advice on reporting interests from private equity funds.
  • Residence and domicile advice, including support on arrival and departure from the UK, and maximising international personal tax efficiency.
  • Advising on the tax treatment of carried interest for UK and non-UK domiciled individuals.
  • Tax efficient ownership structures for co-investment and other fund interests.
  • Personal wealth planning - tax efficient property ownership, family investment companies, offshore trusts, etc.
  • Dealing with HMRC enquiries.

 

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Contact us

Philip Hines
UK Leader of Industry for Private Equity and Sovereign Investment Funds, PwC United Kingdom
Tel: +44 (0) 7801 198620
Email

Richard McGuire
Funds Private Equity Leader, PwC United Kingdom
Tel: +44 (0)20 7212 5838
Email

Darren Docker
Tax Compliance, Tax Structuring, Personal Tax, PwC United Kingdom
Tel: +44 (0)20 7804 6697
Email

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