How BEPS 2.0 could impact the wealth & asset management industry

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.