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International Tax Dialogue, Beijing, 27 October 2009

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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  1. 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

  2. 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

  3. 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

  4. Management Investors Management Fee Carried Interest / Performance Fee Fund Target Companies PEF and HF: The Tax Challenges

  5. 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?

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