Download pdf - Slides 13th Private Equity Forum Luxembourg 5 June 2014

Private Equity Forum

www.pwc.lu

5 June 2014

PwC

Welcome Vincent Lebrun, PwC Luxembourg

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5 June 2014 Private Equity Forum

PwC

Agenda

9:10 – 9:50 Market Update 9:50 – 10:30 BEPS 2014 update for the Private Equity industry 10:30 – 11:00 Coffee break 11:00 – 12:00 Impacts of AIFMD on the Private Equity industry Experiences and trends as from 12:00 Walking lunch

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PwC

Market Update Johan Blaise, PwC Luxembourg

David Garcelan, PwC Luxembourg

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PwC

Agenda

1. Market trends

- Global trends

- Luxembourg trends

2. Fundraising

- Global fundraising

- Fundraising in Luxembourg

3. Investments & Exits

4. SICAR vehicle – Strategy & Operating costs

5. Looking forward

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PwC

Market trends

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PwC

Global trends

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PwC

Global trends at a glance

Section 1.1 – Global trends

1. Better macro conditions (but abnormal conditions in financial markets)

3. Investor confidence. In 2013, global fund raising up by 21%

2. Asset class keeps on performing. 14.4% average IRR by Jun’13

4. Bigger funds but less amount of funds

6. Strong M&A activity. $599.1bn global deals value in Q1 2014

7. High prices. Average EBITDA multiple in 2013 for global M&A deals: 12.6x

8. Exit mood.$111.9bn PE exits value on Q1 2014. This is the highest value in the historic series since Q1 2001

9. Regulatory landslide & shifting tax landscape

5. Management fees & carry under increasing pressure from LPs

Source: Mergermarket M&A trend report Q1 2014

Source: Mergermarket M&A trend report 2013

Source: Bain & Company Global PE report 2014

Source: Bain & Company Global PE report 2014

Source: Mergermarket M&A trend report Q1 2014

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PwC

Inflationary forces

Section 1.1 – Global trends

Economic

“stability”

Cheap

credit

Dry powder

& liquidity in

corporates

Strong

public

markets

High

prices

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PwC

Luxembourg trends

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PwC

SIF and Part II funds

Section 1.2 – Luxembourg trends

2013 vs 2012 Assets : + 35% # sub-funds: + 39 %

As at end 2013, 91% of PE/VC sub-funds are structured via a SIF, owing 96% of assets

2 1 1 0.7 0.5 0.8 1.1

2 3

8 10

12

17.6

23.8

27 24

18 18 13 16 31

20

57

104

136

166

237

321

0

50

100

150

200

250

300

350

0

5

10

15

20

25

30

2007 2008 2009 2010 2011 2012 2013

Nu

mb

er

of

PE

su

bfu

nd

s

EU

R b

illi

on

Assets SIF Assets Part II # Part II # SIF

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PwC

The SICAR A successful vehicle for private equity structuring


2013 vs 2012 Assets : - 4% # SICAR: + 5.5 %

12

17 20

16

21

30 26.6 25.4

91

151

182 200

235

267 273 288

0

50

100

150

200

250

300

350

0

5

10

15

20

25

30

35

2006 2007 2008 2009 2010 2011 2012 2013

Nu

mb

er

of

SIC

AR

s

EU

R b

illi

on

Total NAV EUR # SICAR

2013 vs 2012 # subfund 2012 : 337 # subfund 2013 : 363

+8%

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PwC

Private Equity Funds: Luxembourg market overview


2 1 1 0.7 0.5 0.8 1.1 2 3

8 10 12 17.6

23.8 17 20 16

21

30

26.6

25.4

0

10

20

30

40

50

60

2007 2008 2009 2010 2011 2012 2013

EU

R b

illi

on

AuM PE funds/SICAR

SICAR SIF Part II

27 24 18 18 13 16 31 20 57 104 136 166

237

321

182

221

240 266

301

337

363

0

100

200

300

400

500

600

700

800

2007 2008 2009 2010 2011 2012 2013

Nu

mb

er

of

PE

su

bfu

nd

s

# PE subfunds

SICAR SIF Part II

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PwC

Geographic origin of sponsors is dominated by 4 jurisdictions


0

10

20

30

40

50

60

70

# PE funds

Origin of promotors

And...

Other EU

countries

Egypt

Russia

Source: CSSF and PwC analysis

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PwC

Largest Luxembourg Private equity funds Promoters


With more than 200 promoters of

Luxembourg domiciled private equity funds, the

market is very diversified.

Promoter SIF/Part II # SICAR # AUM (EUR mio)

Partners Group 2 25 5,3

Universal Investment 8 4,3

Carlyle Group 7 3,5

ARDIAN (prev AXA PE) 4 5 2,8

Oranje-Nassau Energie 1 1,8

LGT Capital Management 10 1,6

Natixis 2 1 1,6

Pictet Funds 18 1,5

Nordic Capital 1 1,4

Oppenheim 10 1,2

At least 22 promotors in

scope of AIFMD

158 AIF at least in scope

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PwC

The Luxembourg Limited Partnership vehicles


End of May 2014: # SCSp : 176 # SCS (created over the same period): 100

1 1

16 17 21

69

88

105

123

148

176

3 11 13

21 28

46 53

64 75

91 100

0

20

40

60

80

100

120

140

160

180

200

# c

om

pa

nie

s c

re

ate

d

SCPp

SCS

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Fundraising

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Global fundraising

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2013: the best year since 2009

Section 2.1 – Global fundraising

• 902 PE funds raised $ 461bn worldwide, 21% increase by contrast to 2012

• Less funds, but bigger funds

104

217

361

547

668 688

320 296 330 382

461

0

200

400

600

800

Global fund raising ($bn)

Source: Bain & Company Global PE Report 2014

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PwC

The trend continues in Q1 2014


13.95% capital raised

18.50% No. funds closed compared to Q1 2013

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PwC

Assets under management


• AuM have increased in 2013 to a staggering $3,466 bn

• The dry powder has increased to $ 1,046bn in 2013 (11.16% up from 2012)

• However, the ageing of capital has improved in 2013: capital deployed & extension of investment periods

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PwC

The asset class keeps on outperforming: 14.4% IRR as at June 2013 for long-term buyout fund returns


Source: Bain & Company Global PE Report 2014 (data provided by Cambridge Associates)

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PwC

Fundraising in Luxembourg

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PwC

Top 10 Worlwilde Private Equity house (fundraising)

Presence of the major players in Luxembourg

Section 2.2 – Fundraising in Luxembourg

Largest Private Equity Fund managers worldwide ranking by level of past 5 years fundraising

# Company Headquarter

location

PE structure

domiciled in

Luxembourg?

1 TPG Capital USA YES

2 The Carlyle Group USA YES

3 Blackstone Capital Partners USA YES

4 KKR USA YES

5 Warburg Pincus USA YES

6 Goldman Sachs & Co USA YES

7 Advent International USA YES

8 Apollo Global Management USA YES

9 Bain Capital USA YES

10 CVC Capital Partners UK YES

“Top 10 Private Equity fund

raiser worldwide

have structures domiciled in

Luxembourg”

Source : PEI 300 and Pwc Analysis

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PwC

Top 5 European Private Equity firms (fundraising) Presence of the major players in Luxembourg


Largest Private Equity Fund managers european ranking by level of past 5 years fundraising


location

PE structure

domiciled in

Luxembourg?

1 CVC Capital Partners UK YES

2 BC Partners UK YES

3 Bridgepoint UK YES

4 PAI Partners FR YES

5 Ardian (prev. Axa Private Equity) FR YES

“All major European

player have a presence in

Luxembourg”

Source : PEI 300 and Pwc Analysis

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PwC

Top 15 Fund of Private Equity funds firms


Largest Fund of Private Equity Fund managers worldwide


location PE funds domiciled

in Luxembourg?

1 Alpinvest Partners Netherlands No

2 Goldman Sachs Asset Management US No

3 Harbourvest Partners US No

4 Credit Suisse AM US Yes

5 Partners Group Switzerland Yes

6 Hamilton Lane Advisors US Yes

7 JP Morgan PE Group US Yes

8 Pantheon UK Yes

9 Ardian (prev.AXA Private Equity) France Yes

10 LGT Capital Partners Switzerland Yes

11 Adam Street Partners US Yes

12 Capital Dynamics Switzerland Yes

13 Blackrock US Yes

14 Neuberger Berman US No

15 Lexington Partners US No

“10 of the top 15 Fund of Private

Equity fund managers

worldwide have funds domiciled in Luxembourg”

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PwC

Luxembourg private equity funds size (commitment)


0

5

10

15

20

25

30

35

Nu

mb

er

of

SIC

AR

s

Size above EUR250 mios

Size below EUR100 mios

#SICAR Total SIZE

(EUR) bn

Above EUR 250 mios 40 25

Between EUR 100 mios &

EUR 250 mios 45 7

Below EUR 100 mios 188 6

Total 273 38

Total

unfunded

EUR 9.6 bios

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PwC

Investments & Exits

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PwC

Investments

Section 3 – Investments & Exits

• According to Preqin, 688 private equity-backed buyout deals with an aggregate value of $80bn announced in Q1 2014

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PwC

Exits

Section 3 – Investments & Exits

• Exits for $87bn in Q1 2014

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PwC

SICAR vehicle – Strategy & Operating costs

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PwC

SICAR investment strategies

Section 4 – SICAR vehicle – Strategy & Operating costs

Buy Out 50.8%

RE 20.4%

VC 16.9%

Mezzanine 4.6%

Sustainable 4.6%

Microfinance 1.5%

Not specified 1.2%

Recent asset class

Debt funds

/Distressed debt

Agriculture/farming

Art

Source: PwC analysis

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PwC

SICAR investment structure


Source: PwC analysis

Investment

Structure

AUM Unfunded Avg # invest.

Direct

investments

EUR 18 bios EUR 3.5

bios

9

FoF EUR 9 bios EUR 5.6

bios

11

64%

36%

Directinvestments

FoF

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PwC

SICARs legal forms


SA 21%

Sarl 11%

SCA 63%

SCS 5%

SA

Sarl

SCA

SCS

Large majority of

SICARs adopted

the SCA form.

SCSp ?

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PwC

Management fees and operating charges


Low High Average

0.5% 3.5% 1.70%

Low High Average

0.10% 5.5% 1.13%

• Management fee rate (on commitments)

• Total operating expenses on total assets (Administration, Custodian, Legal, Professional fees)

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PwC

The custody market is fragmented with more than 40 banks providing services


• A large number of players provide custody services to SICARs and PE Funds (SIF or Part II Funds) but however not all are “actively” marketing such services.

• Some banks have invested in dedicated IT system as well as dedicated teams (separate PE/RE department)

• Impact of new PSF status to act as depositary for PE assets?

• Fees (based on total assets)

Low High Average

0.01% 0.96% 0.14%

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PwC

Central administration services


• Functions done by local office usually include supervision of service providers, reporting to investors, …

• Fees (based on total assets)

Low High Average

0.03% 1.40% 0.34%

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PwC

Looking forward

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PwC

What are the forces that will shape PE over the next few months?

Section 5 – Looking forward

Liquidity in market (incl. an historic level of dry powder) will likely keep driving prices up

Fierce competition for deals

Less conventional deals (e.g. minority stakes, partnerships, investments in small companies, amalgamations, etc.)

Exit mood

FED tapering program

Increase in interest rates?

Possibility of debt crisis?

Bubble in public markets?

AIFMD, FATCA, BEPS, proposal to amend the parent/subsidiary directive, etc.

1. High prices 2. Macro trends ! 3.Regulation & tax

Source: PwC Germany PE trend report 2014

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Thank you

PwC

BEPS 2014 update for the Private Equity industry Caroline Goemaere, PwC Luxembourg Vincent Lebrun, PwC Luxembourg David Roach, PwC Luxembourg

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PwC

BEPS for Private Equity

BEPS in the public eye

• Continuing media focus on tax planning by major corporates (Apple, Google, etc.), plus lots of political momentum, means BEPS must be seen as “climate change”, rather than a short-term phenomenon

• The BEPS initiative is increasingly causing some countries to take assertive unilateral action, introducing new laws to deal with issues (e.g. to deny deductions if the income is not taxed elsewhere)

• Many tax authorities, now emboldened by BEPS, are looking to increase challenges of taxpayers’ strategies

• Shareholders, group management and boards will increasingly ask those who manage a group’s tax about its current position and the potential impact of BEPS

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PwC

BEPS for Private Equity

Which bits might bite (worst)?

Funds Fund managers

4 Limit base erosion via interest deductions

Leverage of deal structures

5 Counter harmful tax practices

Rulings Rulings?

6 Prevent treaty abuses WHT mitigation WHT mitigation

7 Prevent artificial avoidance of PEs

Mobile senior employees

8-10 Transfer pricing to be in line with value creation

Brand value, sub- advisory fees

13 TP documentation – country by country reporting (CbCR)

Visibility of structures, much more documentation

Disclosure of global value chain

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PwC

EU Commission – the “early adopter”

Proposal for an EU Parent/Subsidiary Directive general anti-avoidance rule - “GAAR”

• EU Commission put out proposals on 25 November 2013 to amend the P/S Directive, by adding a “GAAR” that would withdraw Directive benefits if there are “artificial arrangements … do not reflect economic reality”

• Aims to “overwrite” the CJEU’s Cadbury Schweppes doctrine. Any EU intermediate holding structure would be at risk, unless it could be asserted with confidence that structure was not in place “for the essential purpose of obtaining an improper tax advantage”?? The GAAR would have a “blunderbuss” effect, until new CJEU cases clarified

• This all might mean that only Luxembourg “regional HQ” structures, with high-level management from Luxembourg of the businesses of companies owned by a Lux Holdco, would be GAAR-safe?

• The GAAR requires unanimity of EU MSs before it can be adopted into the Directive – while this is very unlikely in the short term (6 May decision to defer until Italy EU Presidency), the EU Commission is unlikely to give up, notably given similarity of March 2014 OECD BEPS treaty abuse proposals

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PwC

BEPS – where are we now?

OECD 2014 publication of Discussion Draft reports

30 January Action 13 – Transfer Pricing Documentation and Country-by-Country Reporting (“CbCR”) (20 pages)

14 March Action 6 – Preventing the Granting of Treaty Benefits in Inappropriate Circumstances (“Treaty Abuse”) (31 pages)

19 March Action 2 – Neutralise the Effects of Hybrid Mismatch Arrangements (Treaty issues – 14 pages; Domestic law issues - 79 pages)

24 March Action 1 – Address the Tax Challenges of the Digital Economy (81 pages)

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PwC


The Action Plan – due by 30 September 2014

The Action Plan – due by 30 September 2015

Action 5 Harmful Tax Practices / Compulsory Spontaneous Exchange of Rulings (phase 1) – Review of Member Country regimes

Action 8 Transfer Pricing of Intangibles – Draft of changes to OECD TP Guidelines (and Model Convention?)

Action 15 Develop a Multilateral Instrument – Report on international law and tax issues

Action 4 Limit base erosion via interest deductions - Report recommending design of domestic rules

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PwC


Transfer pricing documentation and CbCR

• Would require all MNE groups to prepare and maintain contemporaneous TP documentation in the form of a group “master file” and “local files” with OECD-specified detailed content

• Per the Discussion Draft, CbCR template would show – on a per company basis – sales, profits, intra-group flows, as well as “economic indicators” including fixed assets, employee numbers, total salary bill and 25 highest paid. Would be available to all tax authorities and give them much greater transparency

• Much opposition, including indications that US IRS has concerns that “global formulary apportionment” could in practice arise. “25 highest paid” reporting likely not to happen. CbCR template not to be part of “master file”? 19 May 2014 public hearing at OECD – major debate on whether all tax authorities should be able to force local affiliate to file all CbCRs, or whether CbCRs got filed with tax authority of group parent, and other tax authorities only got via “exchange of info” mechanisms

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PwC


TP documentation and CbCR – implications for Private Equity

• Where Private Equity houses had their profits taxed would be much more transparent to tax authorities – e.g. what share of overall fee income ended up at local deal sourcing functions?

• Within individual investments operating multi-nationally, financial reporting systems would need to be adapted/upgraded to be able to generate contemporaneous “master files”, CbCR templates, and “local files”

• Within individual investments operating multi-nationally, again a possible greater exposure to TP audits, because how profits were shared between countries would under CbCR be much more transparent to tax authorities – as would any “ruling” that confirms an allocation of profit to a territory (this would also have to be reported as part of CbCR)

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PwC


Hybrid mismatches

• Two papers – longer one complex, recommending changes to domestic laws – shorter treaty changes one has less impact, refers to other BEPS Actions

• Identifies specific situations that should be caught – “D/NI” (deduction/no inclusion) and “DD” (double deduction) – covers both individual financial instruments with hybrid characteristics, hybrid entity payments,

• Overall approach recommended is for “paying country” to deny deduction if recipient country doesn’t tax as ordinary income. If this treatment is not applied a “secondary rule” comes into play, and the “recipient country” must either tax income (if D/NI) or deny the deduction (if DD).

• Discussion Drafts are highly technical. Initial reaction is that rules are similar to those adopted/proposed in UK/NL/F/AUS/Germany etc., or (for hybrid entities) US “dual consolidated loss” rules. Concerns – inconsistency in adoption, complexity, impact on internal financing harms growth?

• Complex “imported mismatch” rules may mean that PPL/CPEC/equivalent financing of Luxembourg platforms eventually have to be re-examined

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PwC

Preventing treaty abuse

The OECD 14 March Discussion Draft – treaty shopping

Source State

Bad Land

Source State

Bad Land

Good Land

Income flow

Income flow

“Treaty shopping” – a person who is a resident of a third state (e.g. Bad Land) attempting to access indirectly the benefits of a treaty (e.g. Source State and Good Land)

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PwC


The OECD 14 March Discussion Draft – preventing treaty abuse

• Far-reaching and extreme - sees any inclusion of any intermediate country in an income flow as “treaty shopping” – OECD has “gone nuclear”?

• New Model Treaty clause would contain

- Very restrictive US-style “limitation of benefits” regime – no “derivative benefits” rules, limited let-outs for “active trade or business” flows; AND

- “Main purposes” test for denial of benefits (i.e. no treaty benefits if one of the main purposes of an arrangement was getting treaty benefits) – a GAAR!

• Also has many other proposals to counter tax-driven structuring – e.g. a blunt overall “effective rate of tax” rule to deny treaty benefits to flows to “low-tax” branches, no treaty benefits at all for “dual resident” companies

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PwC

Limitation-on-Benefits proposals – “active conduct of trade or business” let-out

S State Company

P State Company

Source state Partner state

No need to be Qualified Person

Active conduct of trade or business IN P STATE

Income in connection with or incidental to P State trade or business

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PwC


The BEPS “main purposes” GAAR

“Notwithstanding the other provisions of this Convention, a benefit under this convention shall NOT be granted in respect of an item of income,

if it is reasonable to conclude, having regard to all relevant facts and circumstances,

that obtaining that benefit was ONE of the MAIN PURPOSES of any arrangement or transaction that resulted directly or indirectly in that benefit,

unless it is established that granting the benefit in these circumstances would be in accordance with the object and purpose of the relevant provisions of this Convention.”

Draft paragraph 6 of Art [X] OECD Model Tax Treaty

“Entitlement to Benefits”

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PwC


The BEPS “main purposes” GAAR – some words of slight comfort

• “… where an arrangement is inextricably linked to a core commercial activity, and its form has not been driven by considerations of obtaining a benefit, it is unlikely that its main purpose will be considered to be the obtaining of that benefit.”

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PwC

Preventing treaty abuse – where are we now?

How badly could it affect Private Equity – really?

Interest flows – Non-EU deals

Fund vehicle (e.g. English LP)

LuxCo(s) (Luxembourg)

Investors

DealCo (Deal State)

Target (Deal State)

classes of shares NO WHT

X

Bank NO WHT

X WHT – Fund vehicle is not a “qualifying person”, so LuxCo(s) denied treaty benefits

Assuming Bank is “qualifying person”

DEDUCTIBLE? 2015 BEPS recommends on “interest capping”

• Deal State is non-EU • All Deal State treaties have

March 2014 BEPS anti- “treaty shopping” text

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PwC



LuxCo(s) (Luxembourg)

Investors

DealCo (EU State)

Target (EU State)

classes of shares NO WHT

Bank NO WHT

NO WHT so long as EU I & R Directive still applies

Assuming Bank is “qualifying person”

DEDUCTIBLE? 2015 BEPS recommends on “interest capping”

• Deal State is EU • All Deal State treaties have

March 2014 BEPS anti- “treaty-shopping” text

• EU I & R Directive does NOT yet include any GAAR


Interest flows – EU deals

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PwC



LuxCo(s)

Investors

DealCo

Target

Exit gain is TAXED if Deal State domestic rules tax non-resident sellers of shares. No treaty protection

WHT (non-treaty rate) Fund vehicle is not a “qualifying person”, so LuxCo(s) denied treaty benefits

• Deal State is non-EU • Deal State treaty with

Luxembourg has March 2014 BEPS anti-“treaty shopping” text

classes of shares

X


Dividend flows and exits – Non EU deals

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PwC



LuxCo(s)

Investors

DealCo

Target

Exit gain is TAXED if Deal State domestic rules tax non-resident sellers of shares. Fund vehicle is not a “qualifying person”, so LuxCo(s) denied treaty protection

NO WHT so long as EU P/S Directive still applies

• Deal State is EU • Deal State treaty with

Luxembourg has March 2014 BEPS anti-“treaty shopping” text

• EU P/S Directive does NOT yet include any GAAR

classes of shares


Dividend flows and exits – EU deals

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PwC


Reaction, and compromise?

• Strongly negative response from public consultation (e.g. BVCA)– proposals would deny treaty benefits to most non-publicly traded groups with foreign shareholders, and almost all Private Equity fund structures

• The Draft we now see is probably the “high water mark” - public consultation outcry has emphasised the overkill, and that international trade and cross-border capital flows could be damaged . “Turning the clock more than 50 years back”. Contravenes EU treaties?

• Need to get back to a situation where holding companies with “genuine economic activity” still get treaty benefits? Much pressure for a less restrictive Model “LoB” clause? More help for fully regulated funds, which ought to be “qualifying persons” – linking to 2010 OECD work on CIVs?

• Tax authorities also have yet to have direct input – the OECD needs consensus, and this will not be easy… e.g. US won’t accept “main purposes” rule, or “blunt instruments”?

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PwC


CIV Fund vehicle = UCI - fully

regulated???

LuxCo(s)

Investors

DealCo

Target

BUT Deal State treaty benefits might still be denied if Deal State sustains argument that interposition of LuxCo(s) had as a “main purpose” the getting of treaty benefits

BUT moderation may only help Part II SICAVs, not SIFs or English LP’s / tax neutral vehicles?

classes of shares

Fund house

ManCo / GP

… THEN LuxCo’s would not automatically be denied access to Deal State treaty

Private Equity – what needs to happen?

IF OECD BEPS anti- “treaty shopping” text is moderated to allow CIV’s to be “qualifying persons”…

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PwC


CIV Fund vehicle

Lux “HQ”Co

Investors

DealCo

Target

Lux “HQ”Co continues to get treaty benefits because EITHER CIV is “qualifying person” AND Lux ”HQ”Co is not caught by “main purposes” test OR (automatically) if “active conduct of a trade or business” entitlement can apply – more likely if broadened to a “genuine economic activity” test. (“Main purposes” test would not then be relevant)

Fund house

ManCo / GP

“HQ”Co does all strategic management of DealCo’s, BUYING IN managerial expertise from Fund House / GP / ManCo

DealCo DealCo DealCo

Target Target Target

Service fees

(less fees)

SUBSTANCE

Private Equity – what needs to happen?

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PwC

The way forward

More broadly - what is likely to happen?

• BEPS won’t go away - but it certainly won’t happen as fast as the OECD - or the EU Commission - want

• Many countries will be highly resistant to changing long-established distinguishing features of their tax system

• Governments will all still try to attract and retain “mobile capital”

• If the US doesn’t make big changes, then BEPS is less likely to cause real “top-down” change to the global tax and transfer pricing “framework” (OECD Model Treaty, OECD TP Guidelines)

• Change at “framework” level most likely to be agreed where it moves towards the way the US already does things (e.g. LoB clauses in treaties)

• Most change will come “bottom up” (unilateral action by individual countries – e.g. more anti-abuse rules, stopping “hybrids”, new “interest capping” rules) but having been helped by BEPS –so there may still be “mismatches”

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PwC

The way forward

More broadly - what is likely to happen for Private Equity?

• For Private Equity – main “substance” in “platform”? At least part of GP activity moving to “platform”?

• More Lux UCIs as fund vehicles – if fully-regulated fund vehicles were to become “qualified persons” not caught by “Limitation of Benefits”, but other fund vehicles (e.g. those only affected by AIFMD) remained caught?

• Ever-tightening limitations on base erosion using interest payments would further “moderate” returns that Private Equity funds could generate?

• In Luxembourg - December 2013 Coalition Programme promise - further steps to be taken to attract major Private Equity funds – what will/can the Luxembourg government actually do – how effective will BEPS and the EU be in curbing “tax competition”?

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PwC

Impacts of AIFMD on the Private Equity industry Experiences and trends James Bermingham, Aztec Financial Services S.A Johan Blaise, PwC Luxembourg Jean-Christian Six, Allen & Overy Luxembourg Moderated by: Xavier Balthazar, PwC Luxembourg

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PwC

Thank you

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