Expertise
Financial Tax
Fund structuring, carried interest arrangements, financial product taxation, and financing operations.
We advise fund managers, institutional investors, and financial institutions on the tax structuring of investment funds, financial instruments, and financing operations, on both sides of the fund relationship.
Key Services
Fund Structuring
We advise fund managers and sponsors on the tax structuring of private equity, venture capital, private debt, real estate, and infrastructure funds. Our work covers the full lifecycle, from selecting the optimal legal form and tax regime at launch, through investor onboarding and ongoing compliance, to exit and wind-down. We structure vehicles to achieve tax transparency and efficiency at both the fund and investor level, taking into account the specific constraints of institutional, sovereign, and private investors across multiple jurisdictions.
Carried Interest & Management Packages
We design and implement tax-efficient compensation structures for fund managers and key executives including carried interest arrangements, BSPCEs, BSAs, management packages, and co-investment vehicles. Our advice balances the interests of sponsors and management teams, ensuring that structures qualify for the most favorable tax treatment while remaining fully compliant with regulatory requirements. We also advise on the tax consequences of secondary transactions and restructurings affecting management incentives.
Financial Product Taxation
We analyze the tax treatment of complex financial instruments, derivatives, structured notes, convertible bonds, hybrid securities, and synthetic products, across each layer of the structure and each relevant jurisdiction. Our work addresses qualification issues, withholding tax implications, and the interaction between domestic rules and treaty provisions. We advise both issuers and investors on the tax consequences of financial innovation, including the impact of anti-avoidance measures and regulatory reclassification risks.
Financing Operations
We advise on the tax dimensions of structured finance, acquisition finance, securitization, and intra-group lending, including interest deductibility limitations, thin capitalization rules, withholding tax optimization, and the structuring of cross-border debt and equity flows. Our team anticipates the fiscal constraints that can affect transaction economics and works alongside financial advisors and arrangers to design structures that are both tax-efficient and resilient to regulatory scrutiny across jurisdictions.
Our Approach
Financial tax sits at the confluence of domestic tax law, international treaty networks, and financial regulation. We combine technical depth with a clear understanding of how structures work in practice, advising both funds and their investors to ensure coherence across every level of the structure. We also work with many trusted bankers, in France, the UAE, Switzerland, the US, and more to ensure a global attention to our clients financial matters.
