Untangling the complexity of Pillar Two for investment funds

Ashurst Legal Outlook Podcast

This episode answers many of the most pressing Pillar Two questions that investment fund managers are asking.

As investment fund managers grapple with the potential impacts of Pillar Two legislation, a select group of Ashurst’s tax experts have compiled this podcast to demystify the details.

Adnand Sulejmani offers a brief overview of the Pillar Two legislation, its original intent and how it is enforced in Luxembourg. He also explains how to determine whether an investment fund falls within the scope of Pillar Two, including potential exemptions that exist. Alexandra Clouté explores what implications Pillar Two has for widely held and closely held Luxembourg investment funds. She also emphasises that, whatever scenario a fund finds itself in, it’s vital that fund managers perform due diligence and verify the consolidation status with investors to ensure that there are no unforeseen issues.

Patricia Allen points out that Pillar Two is more likely to apply for single investor funds or segregated mandates, and Alastair Ladkin explains how fund managers are already responding, including: making investors aware of Pillar Two, sourcing information to determine how Pillar Two applies, and deciding how to treat Pillar Two costs.

This is the first in a mini-series of episodes tackling tax issues and investment funds. To listen to this episode and subscribe to future episodes, search for “Ashurst Legal Outlook” on Apple Podcasts, Spotify or wherever you get your podcasts.

The information provided is not intended to be a comprehensive review of all developments in the law and practice, or to cover all aspects of those referred to. Listeners should take legal advice before applying it to specific issues or transactions.

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