International Private Fund Formation Brochure - SJ Berwin

Structuring carried interest
and incentive arrangements
and co-investment schemes
Structuring carried interest for investment team members – especially in pan-
European/global funds – can be a complicated exercise, but tax-efficient
incentives are a critical part of the fund structuring process. With over 20
years’ experience across Europe and elsewhere, we pride ourselves on being
the leading experts on carried interest technology and are often involved in
shaping the laws which govern it.
For clients who are not investing external funds, we advise on structuring
incentive arrangements and co-investment schemes; there can be advantages
in restructuring internal arrangements with the objective of giving investment
executives a tax-efficient incentive to maximise the ultimate value of the portfolio.
For example, in France we have expertise in the structuring of carried interest
to allow French executives to benefit from the new tax regime on the carried
interest derived from pan-European/global funds.
In each jurisdiction, we possess the best legal and tax teams to offer our
clients the best structures. The structures we propose for carried interest and
incentive arrangements and co-investment schemes are designed to address
the need for internal flexibility, regulatory constraint, tax efficiency, succession
and vesting issues.
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