The establishment of the International Financial Services Centre (IFSC) in Dublin in the late 1980s was the start of Ireland’s journey as a leading fund domicile and servicing hub for the asset management industry.
The industry has rapidly evolved since then and assets under management in Ireland reached over €3 trillion in August of 2020. With this number set to continue to increase in the context of an evolving global tax landscape, it has never been more important to have a clear understanding of the range of relevant tax issues and have a clear strategic approach in relation to tax.
Tax & Asset Management
Managing tax issues is a crucial consideration in the context of any investment structure. In our experience, addressing tax issues in isolation from the investment strategy and operational plans can give rise to an unworkable solution from a commercial perspective. Our broad industry experience ensures that we provide tax advice in the context of any broader commercial, legal or regulatory considerations, ensuring our advice can be easily implemented.
There has been a significant shift in the global tax landscape in recent years with various OECD and EU tax initiatives announced and / or in the process of being implemented. Through a combination of our existing client base and participation in various industry groups, our Asset Management tax practice is at the forefront of tax and other developments potentially impacting the sector. Simply put, we understand the tax issues that can arise for industry participants and we have a proven track record of working with market leading clients to manage these issues. We provide tax advice that stands the test of time in a constantly changing tax environment.
KPMG has the largest tax practice in Ireland with over 500 professionals and 36 tax partners. We are widely recognised as the tax adviser of choice in Ireland. Our extensive experience in the investment management sector means that we are confident we can assist with any tax issue that could arise.
What can we do for you?
KPMG Ireland’s Asset Management tax practice advises Irish and international funds, investment managers, wealth managers, investors and fund service providers on the full spectrum of tax issues arising across fund, investment and investor level. We assist clients with tax issues across all of the key industry sub-sets including private equity, hedge funds, exchange traded funds, credit, property and renewable energy.
We can provide assistance with tax compliance or advisory issues impacting funds or the various stakeholders. Our services include:
- Tax structuring at fund and investment level
- Assessing tax implications of fund reorganisations and redomiciliations
- Withholding taxes, reclaims, & completion documentation (e.g. W-8 documentation)
- International capital gains tax reviews in context of FIN 48 and IFRIC 23
- Reviewing tax treaty eligibility of fund and other structure vehicles
- Assessing impact of international tax developments on fund structures (such as anti-hybrid rules, introduction of Multi-Lateral instruments, etc.)
- Irish tax registrations
- FATCA, CRS and other AEOI services
- Fund level tax compliance including VAT and payroll tax compliance
- Review of tax sections of prospectus
- Assistance with US tax investor considerations (e.g. check-the-box approach)
- Investor tax reporting including UK, US (PFIC and K1’s), Swiss and Austrian reporting
- Assisting with investor tax queries
- Advice in relation to carried interest or other management fee arrangements
- VAT analysis of proposed fee arrangements and services
- VAT recovery reviews
- Transfer pricing reviews (e.g. in relation to management fee arrangements)
- Corporate tax compliance for management companies and any SPVs in fund structures
Get in touch
The Asset Management Tax team is always at hand and welcome the opportunity to discuss your asset management requirements to find the appropriate solution for you.
Partner, Financial Services
KPMG in Ireland
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As a jurisdiction, Ireland has a reputation for product and market innovations coupled with strong investor protection measures.
As a jurisdiction, Ireland has a reputation for product and market innovations coupled....