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Private Equity and Hedge Funds: The Tax Challenge Presenters: Marcello Distaso, Netherlands Geoff Lloyd, OECD Philip West, United States Chair: Samuel Tanner, Switzerland . International Tax Dialogue, Beijing, 27 October 2009. The Common Bond of Private Equity (PEF) and Hedge Funds (HF).

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International Tax Dialogue, Beijing, 27 October 2009


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international tax dialogue beijing 27 october 2009

Private Equity and Hedge Funds: The Tax ChallengePresenters: Marcello Distaso, Netherlands Geoff Lloyd, OECD Philip West, United States Chair: Samuel Tanner, Switzerland

International Tax Dialogue, Beijing, 27 October 2009

the common bond of private equity pef and hedge funds hf
The Common Bond of Private Equity (PEF) and Hedge Funds (HF)
  • Convincing definitions for PEF and HF and their business activities are hard to find
  • A clear distinction between PEF and HF is hardly possible
  • PEF and HF belong to the collective investment vehicles family (CIV)
  • In contrast to other CIV: personal financial engagement of the manager in PEF and HF
distinctive features between pef and hf
Distinctive Features between PEF and HF
  • Different views with regard to the investment strategy
  • PEF: - rather long-term perspective

- investment in start-up companies or / and M&A-

companies

  • HF: - rather short-term perspective

- investment in liquid securities or / and derivatives

pef and hf the tax challenges

Management

Investors

Management Fee

Carried Interest /

Performance Fee

Fund

Target Companies

PEF and HF: The Tax Challenges
key questions for session 9
Key Questions for Session 9
  • The tax treatment of the different players and of the

different proceeds: what is the current state?

  • Do tax regulations cause distorsions or misguided

incentives?

  • Do we need new tax regulations? Are there best

practice solutions in sight?