Fund taxation services | KPMG | QM

Fund taxation services

Fund taxation services

Our tax professionals have experience in a wide range of international and cross border tax issues.

International and cross border tax issues.

It is essential that an investment fund platform is tax neutral to maximise investment returns - tax will be paid by the investors according to their circumstances - as well as being able to demonstrate the appropriate levels of tax risk management are being maintained.

Investment funds are a core focus of KPMG's tax advisory and compliance service in the Channel Islands. We keep our clients up to date with the latest developments in the rapidly evolving field of tax legislation and subsequently assist them with handling the resulting tax compliance burden. We provide practical and understandable advice that highlights the specific issues relevant to our clients' circumstances. 

 

Our experience

Our tax team has experience of cross-border tax issues which affect investment funds that operate globally, and we are used to working with other service providers and as part of KPMG's international network to reflect the global nature of investment funds. 

We regularly advise on offshore and onshore open-ended and closed-ended investment funds. We provide tax advice to managers and their advisers on matters including investment fund structuring, investment acquisition, repatriation of profits and IPO listings. Our client base includes a number of leading private equity houses, property funds, debt funds and other alternative investment structures.

 

How we can help

KPMG's tax services for funds cover a wide range of activities, including: 

  • Initial structuring and viability analysis for investment funds and their related vehicles
  • Cross-border tax planning to minimise tax leakage from underlying investments in different jurisdictions
  • Advice on how to interpret and react to changing international tax rules, including the impact of BEPson investment fund structures
  • Advice on how to manage corporate tax residence and permanent establishment issues for investment fund structures
  • Preparation of tax reporting required by fund investors in a variety of jurisdictions
  • Assistance with global reporting and exchange obligations including FATCA (US and the UK) and the OECD's Commone Reporting Standard (CRS)
  • Reviewing and updating taxation sections in the investment fund's legal and marketing documentation

 

UK Investor Reporting Services

KPMG undertakes to identify whether investment funds meet the definition of an Offshore Fund under specific UK legislation, which is essentially anti-avoidance legislation. In certain complex cases, we seek clearance from HMRC as to the classification of the fund.

Assuming an investment fund is an Offshore Fund for UK tax purposes, KPMG offers a range of services. Firstly, we can prepare and submit the fund’s initial application to HMRC to enter the fund into the Reporting Fund Regime (RFR).

We can then assist with the fund’s annual reporting requirements. This includes preparing the Fund’s reportable income calculations, CISC 2 confirmation and a draft report which the fund can issue to its investors. Alternatively, KPMGs offer an online database where reports can be uploaded and investors have access to the data to include on their personal tax returns.

We provide RFR schedules to a large number of Guernsey, Jersey, Luxembourg, Irish and Cayman fund structures that have UK investors. The purpose of ‘reporting’ this information is to ensure UK resident investors are able to obtain capital gains tax treatment rather than income tax treatment on their disposals of shares or units in the fund. 

 

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