Alistair Godwin and Andrew Yeomans (EY) review three areas of complexity that present challenges to asset managers.
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...
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Alistair Godwin and Andrew Yeomans (EY) review three areas of complexity that present challenges to asset managers.
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...
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:
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