Fund Structuring: Tax Considerations
The INREV Fund Structuring: Tax Considerations course provides a practical understanding of tax aspects to consider when structuring a new vehicle. This 1- day training course, led by Richard van der Linden, Senior Director Capital Structuring at URBZ Capital, provides participants with a good understanding of where fund structuring sits in the tax landscape, as well as key tax drivers of a robust non-listed real estate vehicle structure.
The Attendance Fee is:
€850 for INREV members
€1100 for non-members
If you are not an INREV member and wish to register, please contact INREV Academy.
This course will cover the fundamentals of fund structuring and the key technical tax considerations involved, including distributions, exits and withholding tax, access to tax treaties, as well as substance and anti-abuse rules such as the Principal Purpose Test and beneficial ownership requirements.
It will also examine the key principles of the hybrid mismatch rules and their impact on fund and investment structuring and fund documentation, as well as how AI tooling can be used to boost tax structuring. A number of practical examples of fund structures and the common tax challenges faced when structuring a fund will also be discussed.
With a combination of presentations by industry experts, Q&A and group discussions, participants will learn how to execute and integrate tax considerations into the fund structuring process. The course will end with a case study in subgroups.
The course will cover the following topics:
- Fundamentals of fund structuring
- Examples of common fund structures
- Technical tax considerations (including distributions, exits and withholding tax, tax treaties, as well as substance and anti-abuse rules)
- Key developments in ATAD, implications across jurisdictions and the hybrid mismatch rules
- Common challenges when structuring a fund
Upon completion of the course, participants will be able to:
- Explain the fundamentals of fund structuring and the role each layer of a typical fund structure plays
- Recognise common fund structures and assess their tax implications
- Understand the tax treatment of distributions and exits, including withholding tax and capital gains
- Assess access to tax treaty benefits, taking into account substance requirements and anti-abuse rules such as the Principal Purpose Test and beneficial ownership
- Understand the key principles of ATAD and the hybrid mismatch rules, and their impact on fund structuring
- Identify common tax challenges when structuring a fund and practical solutions to address them
This course is suited for experienced professionals who want to deepen their understanding of the tax implications of fund structuring. This includes, for example, real estate professionals involved in the tax structuring process, tax and legal teams at institutional investors and investment managers, and external tax and legal advisors.
Please note that this is an advanced course. Participants should have several years of experience in the real estate funds industry and a basic understanding of the tax environment for funds.
Location
Before attending the classroom training, all participants must complete a one-hour eLearning module on the INREV Code of Tax Conduct as a prerequisite. This additional eLearning is a stepping stone to ensure everyone is at the same level before attending the advanced classroom training. The module will be provided by INREV after registration and is available free of charge.
This course is open to INREV members and non-members and counts towards the INREV Academy Certificate for Non-listed Real Estate Investments.
Questions about training and education?
Please don't hesitate to contact us.