Sarah Gabbai and Tony Stitt look at the current situation regarding the taxation of offshore funds
The new offshore funds regime has generated a number of technical issues many of which were identified in Elizabeth Stone’s article (‘Offshore funds’ Tax Journal 19 July 2010). It comes as no surprise therefore that practitioners have received a number of queries in this area from the investment management industry since the new regime became effective on 1 December 2009. In particular fund structures such as private equity-style funds Guernsey investment companies Luxembourg Fonds Commun de Placement (FCPs) and ‘Baker’ Jersey Property Unit Trusts (JPUTs) may now be affected by the new regime in ways that were not previously an issue and fund managers should consider the impact of the new regime when establishing one of these structures.
Private equity-style funds
Certain private equity-style funds established...
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Sarah Gabbai and Tony Stitt look at the current situation regarding the taxation of offshore funds
The new offshore funds regime has generated a number of technical issues many of which were identified in Elizabeth Stone’s article (‘Offshore funds’ Tax Journal 19 July 2010). It comes as no surprise therefore that practitioners have received a number of queries in this area from the investment management industry since the new regime became effective on 1 December 2009. In particular fund structures such as private equity-style funds Guernsey investment companies Luxembourg Fonds Commun de Placement (FCPs) and ‘Baker’ Jersey Property Unit Trusts (JPUTs) may now be affected by the new regime in ways that were not previously an issue and fund managers should consider the impact of the new regime when establishing one of these structures.
Private equity-style funds
Certain private equity-style funds established...
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