United Kingdom
Funds
Tax - funds/asset management
BDO provide a full range of tax services to funds across a wide range of asset classes. Our cross disciplinary tax teams can provide support throughout the fund life. We work closely with investment managers to design fund structures responsive to the target investor base and the underlying asset. Our services are underpinned by a strong BDO presence in all major jurisdictions for fund entities and the support of our audit and advisory teams with complementary funds expertise. Please contact one of our fund taxation experts to discuss our full range of fund tax structuring capabilities, taxation advice for investment managers and fund promoters, and fund tax compliance services.
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| Real estate funds | Property is an important asset class within the wider investment fund arena. Our real estate focussed specialist group provides structuring advice and transaction support to a wide range of UK and global real estate funds to minimise their exposure to direct tax, VAT and SDLT/transfer tax leakage on real estate transactions. We have advised upon the establishment of a spectrum of both onshore and, in appropriate circumstances, offshore structures. |
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| Private equity funds | We deliver a full range of tax services to our private equity clients. We seek to structure funds that minimise tax leakage on the extraction of profits to investors. We will also focus on an appropriate structure for the private equity management team including the holding of carried interest and minimising tax leakage on the extraction of management fees. In addition we advise on the structuring of acquisitions to minimise tax leakage on acquisition, through the life of the investment and on exit. We also advise private equity executives on their own tax position. |
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| Equity and bond funds | We provide tax advice to a wide range of traditional types of funds including equity and corporate bond funds, encompassing UCITS funds, authorised unit trusts, OEICs and investment funds. Examples of our work includes advising on the conditions to be met for approval as an investment trust in accordance with the provisions of s842 ICTA 1988 and advising on the accounting and taxation of complex derivative instruments under the IMA SORP. | Angela Foyle |
| Hedge funds | We advise hedge funds on tax efficient fund structures. Our work for hedge fund managers includes securing the investment manager exemption, optimising transfer pricing and clarifying the impact of the revised offshore funds legislation and applying for reporting fund status. |
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| Debt funds | We have noticed an increasing trend amongst fund sponsors to establish debt funds with a view to either originating new real estate (both commercial and residential) loans and other loans or, alternatively, to acquiring distressed and/or non-performing loans at a discount to their face value. |
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| Renewable energy funds | We act for a variety of institutional and retail funds focusing upon alternative asset classes, including, for example, wind farms, waste-to-energy projects and forestry funds. These funds typically offer secure income streams and are often backed by government grants, subsidies, guarantees and/or tax incentives financing environmentally sustainable projects. |
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| Venture capital trusts & EIS funds | Venture Capital Trusts (VCTs) will form an increasing focus of personal tax planning in the context of the new 50 per cent income tax rate and the restrictions on pension tax relief. BDO can guide fund managers through the myriad of HMRC rules to secure the statutory tax reliefs under the VCT rules. Similarly, EIS funds are an effective way to benefit from Enterprise Initiative Scheme tax reliefs, including capital gains tax deferral, whilst providing a spread of investment risk. BDO can advise fund managers on both the fund structure, tax sections of the investment memorandum and tax structuring for investee companies. | David Brookes |
| Inheritance tax funds | Inheritance tax funds are increasingly popular and generally focus on investment in trading businesses to benefit from 100 per cent business property relief after two years. BDO can help structure a suitable fund and prepare the tax sections of the investment memorandum. |
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