In recent years, private equity and the wider fund industry investments have been subject to increasing local country tax challenges, in particular at the time of their exit, in many parts of the world. As governments around the world look for revenue sources to replenish their depleted coffers caused by the ongoing COVID-19 pandemic, inbound fund investments and the underlying cross-border transactions are likely to face an even greater level of tax scrutiny by a broadening group of countries around the world. Against this backdrop, it will be vitally important for the private equity and the wider fund industry to plan ahead with respect to the initial cross-border tax structuring and the subsequent exit scenarios in anticipation of the aggressive tax audits at the exit stage.
Join us for Part 1 of the two-part webinar series on the exit-related taxation of inbound fund investments in Asia, the European Union and Brazil. We will discuss the current tax landscape (and what may lie ahead) pertinent to foreign fund investment exits in the two regions and Brazil. Topics will include:
- Common structures (e.g., treaty-based, onshore special purpose vehicles) used and the relevant tax pressure points
- The adoption of various OECD’s Base Erosion and Profit Shifting (BEPS) minimum standards and recommendations (e.g., DAC6 mandatory disclosure regime in the EU) and its practical impact on the exit-related tax dynamics
- Case studies to illustrate how concepts such as the treaty look-through, holding company substance and beneficial ownership have been applied in practice by local tax authorities
Save the date for Part 2 of our two-part webinar series, “Navigating the Storm – Initial Structuring, Exit Strategies and Tax Controversy Considerations in Asia, the European Union and Brazil,” on June 30, 2020.
CLE is not available when viewing a recording of this program. In order to receive credit you must have attended the live webinar program.