Investment Fund Analysis & Strategy

Investment vehicle – transparent partnership - LP No-Belgian ✓ custody principle "enshrined" in law ✓ X Tax neutrality can be achieved but depends on portfolio structuring and, for BE corporation, on the fulfillment of certain thresholds ✓ Tax exemption of vehicle not limited by eligible investments ✓/X Foreign investors: depends on local tax law ✓ No yearly tax on undertakings ✓ Not subject to asset test but ventilation obligations Belgian resident resident Foreign Co BelCo 1 BelCo 2 PwC GP Fund (scsp) Portfolio 21 21

View entire presentation