Non-confidential version of the EC’s State aid opening decision in GDF Suez published
On 5 January 2017, the European Commission (“EC”) published its opening decision in the formal investigation into Luxembourg tax rulings obtained by entities of GDF Suez. The opening decision dated 19 September 2016 explains the reasons for the initiation of the formal investigation and the additional information requested from Luxembourg in order to reach a
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
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