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How BEPS 2.0 could impact the wealth & asset management industry
In this webcast, panelists will examine how the Pillar Two rules may apply to the wealth & asset management industry and will highlight practical considerations.
Although it is generally expected that the Organisation for Economic Co-operation and Development’s BEPS 2.0 initiative will have a limited direct impact on the investment fund industry, the Pillar Two model rules’ reliance on the accounting consolidation rules to determine whether a group exists will pose additional challenges when determining the scope of these rules.
The Pillar Two rules apply only to entities that consolidate on a line-by-line basis for financial reporting purposes. While investment funds generally do not consolidate with the entities in which they invest, there are certain exceptions that may apply.
The following topics will be discussed:
The current status of the Inclusive Framework’s Pillar Two discussions
Application of the Pillar Two rules to management companies that reach the annual revenue threshold of EUR 750 million, including differences in application between structures whose ultimate parent entity (UPE) is tax transparent and Up-C structures
Practical considerations for investment funds, such as determining the UPE, differences between consolidation requirements under US Generally Accepted Accounting Principles (GAAP) and International Financial Reporting Standards (IFRS), and the concept of excluded entities
Pillar Two considerations for the following fact patterns:
Single managed accounts or funds of one (e.g., insurance groups)
Co-investments with multinational enterprises (MNEs), such as joint-ventures, partially owned parent entities (POPE) and minority investments
Private trusts or personal holding companies for family offices and high-net-worth individuals
Panelists
Kevin J. Glen, Partner, Financial Services ITTS/FSO Central Tax Markets Leader, Ernst & Young LLP
Augusto Oliveira, Partner, Financial Services ITTS, Ernst & Young LLP
Dmitri V. Semenov, Partner, Financial Services ITTS, Ernst & Young LLP
Alex Pouchard, Partner, Financial Services International Tax Desks Leader, Ernst & Young LLP
Kerrie Cadugan, Managing Director, FAAS, Ernst & Young LLP
Moderator
Jun Li, Partner, Financial Services Wealth and Asset Management Tax Leader, Ernst & Young LLP
EY webcast managed and produced by Ernst & Young LLP’s Tax Technical Knowledge Services Group, Washington, DC: Lynn Fairfax.