Carried interest structured via stock option plan – no taxation as professional income at exercise of the option as per Belgian Court
A Belgian Court annulled the tax assessment levied by the Belgian tax authorities regarding carried interest income structured via the means of an option plan. The Belgian tax authorities claimed the setup was fraudulent and simulated and therefore the income gained at exercise of the options should be taxable as employment income. On 27 February
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
