Managed Services for Alternatives

Your challenges

• Management of large number of entities, of stakeholders and various counterparties;
• Staying up-to-date with all regulatory obligations and the change in legal landscape;
• Dealing with accounting standards becoming always more complex;
• Understanding the completion of filing on a regular basis.

How we can help

We possess the technical skills and knowledge for the preparation of timely and high-quality financial statements. We are highly experienced in Luxembourg GAAP, UK GAAP, US GAAP and IFRS reporting for the Alternatives industry.

Our expertise covers the following areas:

• Preparation of Financial statements (Luxembourg GAAP, UK GAAP, US GAAP and IFRS reporting);

• Ensure compliance with local law, regulatory requirements and accounting principles;

• Assistance in the audit process;

• Strong coordination with tax team teams (including possibly the computation of tax provision review);

• Dashboarding to provide the status of preparation / filing for the entire SPV’s portfolio.

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Your challenges

• Need for quality NAV computation and deliverables and working though reduced audit timelines;
• You require staff with market exposure & knowledge regarding best practices in Alternatives;
• Lack of streamlined processes and technology to manage efficiently fund administration tasks;
  
• Limited expertise and staff  to cope with certain asset classes.

How we can help

We can assist with the administration of regulated and non-regulated Alternative Investment Funds focused on Fund accounting and Investor services/ Transfer Agency services.

Our expertise covers the following areas:

Accounting, reporting and consolidation:

• Consolidation and NAV computation (including GAAP alignment and INREV reporting, CSSF reporting); Preparation (and coordination) of statutory (consolidated) annual accounts; 

• Management fee, carried interest, performance fee and other Fund fees calculations (i.e. rebates);

• Management, investor and financial reporting (i.e. Quarterly reporting, Investor bespoke reporting, Bank reporting, Interim situations, etc.);

• Debt portfolio management including forecasting and cash;

• Bookkeeping services for entities located in multiple jurisdictions with global coordination and under various GAAPs;

• Regulatory Reporting (BCL, CSSF, etc.);

• Intercompany transactions management and oversight;

• Provision of accounting and compliance platform with real-time dashboard and drill-down functionalities;

• Investment compliance monitoring.

 Investor services:

• Transfer agency services (register maintenance, investor admission, subscription/redemptions, capital calls, etc.);
• AML/KYC on investors; 
• Investor reporting.

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Your challenges

• More complex legal and regulatory requirements;
• Increasing pressure by regulators over compliance and governance;
• Need for maintaining oversight and tax substance;
• Constant challenges and pressure on the legal function.

How we can help

We assist clients in their company secretary operations and governance obligations. We document management decisions and ensure their compliance with Luxembourg regulatory and operational requirements.

Our expertise covers the following areas (for Fund and Corporate):

• Board meetings (organisation, convening notices, presentation and minutes);

• Preparation of written resolutions at Director/Shareholder level (day-to-day, transactional);

• Entity incorporation & liquidation;

• Bank accounts management and payments processing;

• Document management (contracts/agreements);

• Formalities (power of attorney, managers/directors change, apostilles, business licence);

• Filings with authorities, monitoring and updating (RCS/RBE);

• Domiciliation services;

• Governance consulting (substance, tax audit);

• Non-Executive Directors research.

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Your challenges

• More aggressive tax audit and litigation;
  
• Changing regulatory environment and increasing demand for tax transparency;
  
• Shorter tax filing deadlines and earlier requests for payments;
• Link between your tax and risk management strategy.

How we can help

Well integrated in the network, our tax specialists are dedicated to support you with all the direct tax compliance tasks and ease the follow up using digital tools.

Our expertise covers the following areas:

• Preparation or review of the annual corporate tax returns and related tax forms and schedules;

• Election for specific tax provisions like the reduction of net wealth tax, tax unity, foreign tax functional currency;

• Communication of the tax risks and opportunities resulting from the preparation of the tax returns;

• Liaising with the tax authorities for the assessment phase;

• Coordination with tax consultants during the life cycle of the company;

• Coordination with foreign countries for cross-borders tax compliance assignments;

• Calculation and/or review of tax provision for local reporting and group reporting (including IAS 12, and FAS 109);

• Preparation or review of the withholding tax returns on dividends, director’s fees and subscription tax;

• Information on the tax payments to be made and monitoring of the tax prepayments;

• Assistance in the context of a tax audit from the tax authorities;

• Assistance with tax litigation;

• Tax diligence review for M&A transactions.

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Your challenges

• Indirect tax compliance requirements vary from one jurisdiction to another;
• Wrong reporting can immediately trigger negative consequences;
• Efficient management of indirect tax compliance is very challenging;
• More aggressive tax audit and litigation.

How we can help

An efficient, risk-managed process is in place with a focus on continuous improvement and value add via thorough review of supporting documents against reported data for each VAT return prepared.

Our expertise covers the following areas:

• Preparation and submission of VAT registration/deregistration form, cover letter and appendices;

• Preparation of periodic (monthly/quarterly) and annual indirect tax returns and filing;

• Provision of a findings report flagging (potential) risks and opportunities and their submission;

• Review of the VAT assessment;

• Preparation and submission of EC Sales lists and Intrastat returns;

• Preparation of foreign indirect tax/VAT refund claims (e.g. 8th Directive refund claims);

• Screening of your structure to assess the VAT position of the entities and their VAT obligations;

• Assistance in the context of the VAT audit from the tax authorities;

• Assistance with VAT litigation;

• Coordination with foreign countries for cross-borders compliance assignments.

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Your challenges

• Luxembourg tax authorities increasing audits (in-depth and desktop reviews);
• Transfer pricing documentation enhanced rules to come (2024);
• Variable yield instruments under scrutiny by Luxembourg tax authorities;
• Substance and governance in Luxembourg as priorities (AIFMs and financial intermediation platforms).

How we can help

Our team of transfer pricing specialists is well positioned to advise you on developing compliant structures that help advance your business goals by achieving a 360° view and integral assessment of your intercompany flows with our managed services approach.

You want to identify opportunities to improve efficiency of your transfer pricing functions, with an efficient team that can manage your transfer pricing risks.

Our expertise covers the following areas:

• Financial intermediation activities (remuneration and equity at risk analysis (2017 TP Circular);

• Interest rate benchmarking analysis, inclusive of debt-to-equity and serviceability;

• Reasonability of variable yield analysis;

• Analysis of the value chain of alternative investments;

• Preparation of OECD-compliant transfer pricing documentation.

We can further support you in the following areas:

• Sign-off of approach and methodology by PwC local offices;

• Determination of GP, ManCo AIFM remuneration (Lux proprietary benchmark);

• Assistance in relation to transfer pricing audits; 

• Substance and governance analysis; 

• CFC functional analysis.

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Your challenges

• Based on only certain complex criteria, you may be subject to investor tax reporting;
• Highly complex tax computations for each jurisdiction;
• The interpretation of highly complex regulatory requirements;
• Non-standardised reclassification of accounting figures & financial instruments.

How we can help

We offer a comprehensive, bespoke and efficient tax reporting service for funds looking to satisfy these tax reporting obligations.

Our expertise in Investor tax reporting covers the following regions (examples of main reporting regime):

• Austria: Austrian Tax reporting;

• Belgium: Net Asset Tax, Belgian Taxable Income per Share (BTIS);

• Denmark: Danish Tax Reporting;

• France: PEA regime;

• Germany: German Investment Tax Act, German Partnership reporting;

• Italy: Italian Tax Reporting, Inheritance Tax Reporting, PIR tax-exempt investment plan;

• Norway: Norwegian Tax Reporting;

• Spain: Tax deferral scheme;

• Switzerland: Swiss Tax Reporting;

• United Kingdom: UK Reporting Fund Status (UK RFS).

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Your challenges

• Depending on the type of Investors, domicile and distribution of your funds, you may be subject to regulatory reporting;
• Specific requirements for each reporting to be considered;
• The interpretation of highly complex regulatory requirements;
• Distribution - a success key in Europe!

How we can help

We offer a comprehensive, bespoke and efficient reporting service for funds looking to satisfy these reporting requirements of the investors.

Our expertise covers the following areas:

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Your challenges

• Reclaim process is getting more complex due to reinforced rules from tax authorities;
• Lack of transparency status and follow-ups on the tax reclaims/ reliefs;
• Need to manage many stakeholders with various levels of data quality;
• Administrative burden due to non-harmonized filing process (manual).

How we can help

Our Global Withholding Tax Reclaim Services and dedicated teams can help you tackle challenges faced within the tax reclaim process and capture your refund opportunities.

Our expertise covers the following areas:

• We help in different phases of the tax reliefs/reclaims set up by enhancing the client’s awareness & conducting health checks on the existing activities and investment portfolio;

• We support by developing and transforming the operational tax activities and by running the entire operations or with a focus on specific markets/streams;

• We assist to manage the tax compliance risk and oversight and help at every step of the tax reclaim process by combining our expertise and operational efficiency set-up supported by state-of-the art tools.

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Your challenges

• Financial institutions face increasing scrutiny from tax authorities on quality of information;
• AEOI Due diligence on investors are complex and can impact the onboarding value chain;
• Implementing a reporting system within your company is time consuming and expensive;
• Governance, oversight and effective controls need to be demonstrated to tax authorities.

How we can help

Our AEOI compliance services cover all aspects of your compliance program that need to be implemented to fully comply with your FATCA/CRS obligations.

Our expertise covers the following areas:

FATCA/CRS Classification

Based on the activity of the entity, our expert team delivers a detailed FATCA/CRS classification analysis.

Completion of Self-Certification Form

We provide FATCA/CRS Self-Certification form and U.S. withholding certificate (W-8BEN-E, W-8IMY, etc.) in order to provide them to the financial counterparts.

Due Diligence Assistance

We perform for financial Institutions the FATCA/CRS Due Diligence by reviewing the investors’ documentation in order to prepare the FATCA/CRS Reporting.

FATCA/CRS reporting

We deliver Reporting Financial Institutions with their annual FATCA and CRS reports. These will  disclose some personal and financial information on reportable investors under FATCA and/or CRS. 

FATCA/CRS Tax governance

Our team reviews and advise Financial Institutions regarding their procedures, IT systems and controls in place.

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Your challenges

• Assessment of your reporting obligations is complex and time consuming;
• Local implementations of DAC6 have added extra requirements to comply with;
• Keeping track of your reporting obligations for every transaction is a challenge;
• Governance and oversight on your arrangements (transactions).

How we can help

Our team can help you to understand the rules, implement effective controls and processes to ensure disclosable events are proactively identified, managed and reported.

Our expertise covers the following areas:

Risk Assessment of your arrangements (transactions)

Risk assessment (per business unit) underpinned by a tried and tested methodology to help you asses:

• Key risk areas and processes;

• Applicable hallmarks;

• Your impacted businesses;

• Readiness to comply;

• Review of (a sample) transactions.

Define Governance framework

• Comprehensive documented framework to identify and manage risks and potentially impacted transactions;

• Define roles and responsibilities;

• Draft and review procedures;

• PwC DAC 6 Compliance Solution to assess, monitor and report in-scope transactions. 

Technology and data

• DAC 6 reporting;

• Integrated approach using technology to address multiple reporting requirements using the same data set and reporting mechanism in the required format.

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