Our Investment Funds and Tax practices work closely together to provide alternative asset clients with tax-efficient solutions and advice, including:

• Fund Structuring
  • Acting for sponsors on the tax structuring of the full range of closed and open-ended investment funds across a range of asset classes e.g., private equity, venture capital, real estate, credit/debt etc.
  • Advising sponsors on bespoke investment products e.g., separate managed accounts, co-investment structures, pledge funds, JVs, private capital club deals and other non-blind pool arrangements
  • Structuring to accommodate investors sensitive to regimes including ERISA, UBTI, Solvency II, US PFIC and CFC rules etc.
  • Structuring for anti-tax avoidance developments, including BEPS, ATAD II + III and related issues
• Carried Interest
  • Working with sponsors to design efficient carried interest, management equity arrangements and other incentive arrangements for their investment professionals and wider teams
• Investment Management Advisory
  • Advising investment management groups on their house tax matters, including LLP tax issues, employment tax, VAT advice and transfer pricing
  • Advising on the structuring of cash flows from funds to investment managers, including management fee flows, carried interest and sponsor commitment arrangements, taking account of carried interest and DIMF tax rules
• Transactional and Portfolio Company Structuring
  • Advising on the structuring of investment holding platforms below fund structures
  • Enabling fund sponsors realise tax, cost and operational benefits of structuring their asset holding architecture for UK or non-UK investments under UK QAHC (Qualified Asset Holding Company) regime
  • SSE (Substantial Share Exemption) tax advice for private funds making UK portfolio investments
• Private Tax Planning - Fund Principals and Executives
  • Private tax planning, inheritance and wealth management advice for principals, executives and other investment professionals active within the private funds and asset management industries
• Indirect / LP Secondary Transactions
  • Tax issues arising in indirect secondary transactions e.g., UK stamp duty, US ECI and FIRPTA, tax warranties and indemnities in SPA and transfer documentation etc.
• Tax-advantaged Venture Capital Schemes
  • Advising on tax-advantaged venture capital schemes i.e. Venture Capital Trusts (VCTs), Enterprise Investment Schemes (EIS) and Seed Enterprise Investment Schemes (SEIS)