PwC’s dialogue with Private Equity investors reveals growing interest in responsible investment
There is a growing need for General Partners (GPs) to demonstrate responsible investment behaviour and manage their exposure to environmental, social and governance (‘ESG’) risks in their engagement with Limited Partners (LPs). This trend is also based on the belief that addressing ESG factors will protect value by either improving returns or reducing risk. PwC’s
The Rulings Commission publishes ruling request templates
The Belgian Rulings Commission has recently published ruling request templates. These templates have been prepared in an effort (i) to facilitate access to tax rulings and (ii) for transparency purposes. Ruling request templates have been made available in Dutch and in French for the following relevant transactions: Mergers, Partial demergers, Contribution of a line of
Have you considered the VAT impact when dealing with Transactions?
In today’s tax world, considering VAT in a timely manner is key to limiting the negative impact it can have on your transaction budget. VAT on transactions can lead to either VAT savings or a VAT burden depending on various factors. Recent developments in EUCJ case law that allows VAT deduction for active management holding
Fund structuring – Impact of BEPS
One of the most important decision-making factors that an asset manager (General Partner – GP) considers in setting up a fund is to ensure that the investment structure is tax neutral for its investor (Limiter Partners – LPs) and provides for the most reliable regulatory framework. The complexity of setting up international investment vehicles pooling
Management exit considerations: capital gains tax treatment
Retaining and incentivising the management of portfolio companies is key for private equity firms. Managers will thus invest alongside with investors and enter into some incentive arrangements. At a future exit, they may then expect to walk away from their investment with a significant return. Belgian managers may invest through a personal holding company or
Brazil: Changes to calculation basis of net equity payments and to withholding tax on interest
Here’s a link to a Tax Newsalert with respect to Brazil Taxation you may find very interesting – link This ITS Newsalert reports on Provisional Measure 694/2015, which changes the calculation basis of, and the withholding tax rates applicable to interest on, net equity payments in Brazil. Should you have any further questions on this topic
Allocation of acquisition debt: economic rationale is key!
In today’s tax world, having a strong economic rationale to support an entity’s leverage is key. In our recent experience, the tax authorities look at a company’s gearing in 3 ways: Business purpose test: what is the motivation for each entity taking a loan? TP principles: Is the interest rate at arm’s length considering the
Is your upper-tier structure BEPS-proof?
The OECD BEPS Action Plan and parallel developments impact each layer of a multinational structure, including the upper tier. Specifically, having insufficient relevant substance at upper tier level could cause your return on investment to decrease significantly (by up to 25% based on the current Belgian withholding tax rate). On top, we expect that the
