COVID-19 #6 Cash repatriation – capital reduction
Next to dividend distributions and (early) repayment of intercompany loans, a group may also consider a capital reduction to repatriate cash to the upper tier structure. Whereas a reduction of fiscally paid-up capital is in principle tax neutral between corporates, it may still have some (unexpected) tax consequences. Item #6: A capital reduction is not
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
