International Taxation of Investment Funds

Investment funds face a web of cross-border tax issues: investor residence, fund residence, treaty access, permanent establishment risk, and characterisation of returns. This session explains how different fund vehicles and strategies (private equity, credit, hedge, real estate) interact with withholding taxes, VAT/GST, and reporting. We’ll discuss substance and delegation, feeder/master structures, and common pitfalls in portfolio and management fee flows. We’ll cover investor reporting and operational controls.

This webinar provides one-hour of CPD and offers insights and updates from a leading industry-expert speaker. 

Delegates places are interchangeable with colleagues from the same organisation.

Content

• Treaty access, residence, and PE risk

• Return characterisation and investor outcomes

• WHT and VAT/GST touchpoints across jurisdictions

• Substance, delegation, and governance considerations

• Common structuring pitfalls and controls

Presenter

Romain Tiffon Partner, International & Corporate Tax at ATOZ

Romain Tiffon is a Partner at ATOZ in the International and Corporate Tax department. Romain Tiffon has over a decade of experience in structuring pan-European investments and coordinating tax implementation for a wide range ofa institutional investors in the private equity, real estate and debt sectors. Additionally, Romain Tiffon has extensive experience advising multinational corporations in structured finance matters and corporate restructuring. Also active in North America, he has been admitted to practice as an attorney and counselor-at-law in New York State. Romain Tiffon is a member of the New York State Bar Association as well as a member of the Tax Committee of the American Bar Association.