Bavarians at the gate
Could alternative interpretations of offshoring private equity fund structures spread to other parts of the world?
It’s a headline a private equity journalist can only dream of writing.
As we reported this week, private equity firms based in Bavaria – Germany’s largest state – are facing a threat of punishment and imprisonment in relation to fund domiciling, one of the core components of fund structuring.
The issue at stake is the place of management of a business and the site of value creation, and the Munich tax authority’s interpretation of the law. It claims that fund structures set up abroad are in fact managed in Germany, with the offshore office in place solely to sign documents...
Read the full article on Private Equity International here.