Tax treaty entitlement of non-CIV funds: European Investment Platforms for Private Equity structures as a solution

Tax treaty entitlement of non-CIV funds: European Investment Platforms for Private Equity structures as a solution

Abstract:

The current tax context causes high level of uncertainty around private equity investors and tax administrations. Nowadays, one of the most debated issue is the tax treaty entitlement of investment platforms or holding entities used within the private equity market. This issue has increased its relevance as a result of the recent work from the OECD on BEPS. In this article, we will face this problem and we will provide with some considerations that may help with its solution.

Keywords: Private Equity, Access to Tax Treaties, BEPS, Economic Substance.