Structuring for a new hedge fund

Blick Rothenberg was engaged to advise on the tax structure for a hedge fund.

The advice covered the tax treatment of the UK based investment advisor, the maintenance of non-UK tax residence for the investment manager, and a suitable structure to protect the interests of the ultimate beneficial owners of the investment manager. The non-domiciled status of the beneficial owners was utilised to maximise the tax efficiency of the structure.

Aside from the tax technical issues, broader commercial advice was provided with regard to the contractual relationships between the parties.