The Resource The impact of ATAD 2 on real estate and private equity funds

The impact of ATAD 2 on real estate and private equity funds

Label
The impact of ATAD 2 on real estate and private equity funds
Title
The impact of ATAD 2 on real estate and private equity funds
Creator
Subject
Language
eng
Summary
The EU's second Anti-Tax Avoidance Directive ("ATAD 2" or the "Directive") focuses on preventing hybrid mismatches that result in double non-taxation. Hybrid mismatches are commonplace in the current fund industry. This is mainly because of the wide variety of investors and investment jurisdictions, with each jurisdiction applying their own entity and income qualification rules. ATAD 2 is therefore expected to have a big impact on the real estate and private equity fund sector. In this article, the key risks that fund managers will have to deal with are described. After a brief explanation of the characteristics of the Directive, specific ATAD 2 risks will be discussed using a typical real estate/private equity fund structure as example. Risks include hybrid debt instruments, hybrid funds, platforms and SPVs, as well as double deduction scenarios. The article concludes with the expected trends for a post-ATAD 2 fund landscape
Citation source
In: Derivatives and financial instruments. - Amsterdam. - Vol. 21 (2019), no. 3 ; 22 p
http://library.link/vocab/creatorName
Cabollet, T.C
Geographic coverage
  • European Union
  • Europe
Language note
English
http://library.link/vocab/subjectName
  • ATAD 2
  • hybrid mismatch
  • investment fund
  • real estate investment fund
  • private equity
Label
The impact of ATAD 2 on real estate and private equity funds
Instantiates
Publication
Label
The impact of ATAD 2 on real estate and private equity funds
Publication

Library Locations

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      52.3736660 4.9336932
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