The OECD’s Tax Challenges Arising from Digitalisation of the Economy – Global Anti-Base Erosion Model Rules (Pillar Two) (the ‘Model Rules’) (and local implementing legislation) contain provisions intended to apply to asset management businesses. Key among them is a category of Excluded Entity covering an investment fund that is the Ultimate Parent Entity of the relevant group (see Article 1.5.1(e)) along with certain 95% or 85% subsidiaries of such an Excluded Entity (see Article 1.5.2). The effect of a parent entity (and its subsidiaries) falling within the Excluded Entity definition is to take them outside the scope of Pillar Two.
For many asset managers this may be the primary Pillar Two defence for their fund structures. However it is not a panacea as this article seeks to bring out.
In particular various factors including seed funding can bring a fund vehicle within the same...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
The OECD’s Tax Challenges Arising from Digitalisation of the Economy – Global Anti-Base Erosion Model Rules (Pillar Two) (the ‘Model Rules’) (and local implementing legislation) contain provisions intended to apply to asset management businesses. Key among them is a category of Excluded Entity covering an investment fund that is the Ultimate Parent Entity of the relevant group (see Article 1.5.1(e)) along with certain 95% or 85% subsidiaries of such an Excluded Entity (see Article 1.5.2). The effect of a parent entity (and its subsidiaries) falling within the Excluded Entity definition is to take them outside the scope of Pillar Two.
For many asset managers this may be the primary Pillar Two defence for their fund structures. However it is not a panacea as this article seeks to bring out.
In particular various factors including seed funding can bring a fund vehicle within the same...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
b5c1a11f-e7c0-4890-9c79-3f37c487dc4c.jpg?sfvrsn=e5765d47_1)
