Private Funds Structuring

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Insights on Corporate Tax

Navigating the landscape of domestic and international tax matters is crucial for alternative investment funds seeking to bridge various investor needs, optimize their investment strategies and structure investments in a manner, which from a tax and regulatory perspective is efficient for the fund and its investors, while at the same time ensuring compliance with local and international requirements.

General tax structuring is on the international agenda, and changes to applicable tax legislation are expected over the lifetime of a fund. It is therefore important to ensure a sustainable structure, and that all entities, tax treaties, and EU directives are used in accordance with their purpose (BEPS, ATAD directives, etc.).

We assist alternative investment funds, including private equity funds, infrastructure funds, debt funds, real estate funds and funds investing in other asset classes. We have broad knowledge on the various needs and sensitivities of international investors, and with structuring of investments and repatriation towards a diversified and international investor base.

Katrine Hasselgren Strange

Partner, Corporate Tax

KPMG Acor Tax in Denmark

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What we do

Our team have a broad experience from the asset management side as well as the investor side, M&A transactions and structuring of investments. We provide insights and solutions that help you manage tax risks and enhance the value of your investments for the fund and its investors as a whole.

We provide expert guidance on tax matters during the structuring and formation of alternative investments funds within private equity, infrastructure, debt, real estate and other asset classes.

We offer tax assistance in connection with drafting of fund documentation, incl. limited partnership agreements, Private Placement Memorandums, Management Agreements, Subscription documents, side letter catalog, etc.

We assist alternative investment funds prepare tax memorandums to allow prospective investors to get a better understanding of the fund structure and relevant tax considerations in connection with an investment in the fund, etc.

We assist during onboarding of investors, incl. in connection with investor tax due diligence, negotiations and drafting of tax side letter clauses, etc.

We offer assistance in connection with the structuring of carried interest and co-investment vehicles, incl. taxation and reporting of carried interest as well as other asset manager (AIFM related) services.

We assist with tax due diligence and structuring of underlying investments.

We assist in the development of internal procedures to ensure tax compliance with local and international tax legislation as well as compliance with commitments towards investors, LPA covenants, side letter obligations, etc.

We offer assistance in connection with investor/fund tax reporting, incl. investor requests with respect to additional tax information.

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Meet the Corporate Tax team

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We support institutional investors and asset managers of alternative investment funds through all stages of the fund lifecycle.

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We assist you navigating tax regulation before, during and after a transaction. Whether it is an acquisition or disposal, an initial public offering, restructuring or refinancing.

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