Investment Fund Analysis & Strategy

Investment structure - overview of tax considerations 2 1 - 2 - At the level of investors / managers PwC Manager/ GP 1 Carry Investors / LPs . Taxation / WHT on dividend income or buy-back/liquidation proceeds Capital gain (CG) taxation upon exit • Tax treatment of the CI and taxation of co-investment 3 - At the level of the investment vehicle . Taxation / WHT on dividend income (PEX or credit regime) Equity · Taxation of CGs / deductibility of capital losses Loans Profits ! Equity • Carried interest Controlled Foreign Corporation legislation 3 Advisory company Management fees Bank debt Investment · vehicle 4 Loans • Dividends Equity Portfolio Stamp/capital duties upon capital contribution (in cash or in kind) Deductibility of interest expenses • Interest WHT leakage Deductibility of management fees and related input VAT 4 - At the level of the advisory company • Transfer pricing • VAT aspects . PE exposure • Tax treatment of management fees and/or fund commitments drawdown • Regulatory definition 16

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