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PE funds and master holding companies: traps for the unwary

James Shorland (Alvarez and Marsal) explores some of the unintended UK tax consequences of master holdco structures on portfolio companies of private equity funds. 

It is becoming more common for private equity (PE) funds to structure their portfolio company investments such that they are all held via a single ‘master’ holding company (‘Master Holdco’). The pros and cons of implementing a Master Holdco structure are not covered by this article.

However using a Master Holdco structure can have unintended consequences at a portfolio company (‘Portco’) level. This article explores some of the UK tax consequences for Portcos held via a Master Holdco structure.

What is a Master Holdco structure?

There are many variations of Master Holdco structures implemented by PE funds based on their specific facts and circumstances but put simply these structures involve a PE fund establishing a common holding company through which all of...

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