Investment Fund Analysis & Strategy

PE exposure PwC Context New stricter definition of Agent PE - increased risk that Fund manager/advisory company activities in the target state lead to a local taxable presence (PE) for the fund or its investors. Provides: Manager / GP Investors • Management • Dependent agent PE Provide: services • Technical Capital • Independent agent PE expertise Fund Provides: Capital Target Group Provides: advisory services Advisory company PE exposure Impact for funds • PE exposure is likely to result in double taxation Actual conduct prevails over contractual arrangements 25

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