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PE funds and master holding companies: traps for the unwary

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Private equity funds are increasingly using master holding company structures for their investments. While these structures may offer some benefits from a tax, legal and administrative perspective, they can have unintended effects on the tax position of the UK portfolio companies they hold. This can be through tax grouping provisions, thresholds for tax relieving provisions and additional tax reporting obligations. Careful evaluation of the implications of these master holding company structures prior to implementation is essential.
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