Private Equity Tax Landscape for 2024

Private Equity houses are looking ahead to what developments to expect in the tax landscape for the next 12 months. The upcoming general election is muddying the water, and making future changes difficult to predict.

The question is whether 2024 will bring stability, or change, to the Private Equity tax environment. There has been rhetoric for change to the taxation of private equity managers, with potential reform to the carried interest regime in the event of a change in government. There remain questions over the international taxation of holding structures, with more potential EU anti-avoidance in the pipeline, the introduction of Pillar Two, and the continued embedding of the Qualifying Asset Holding Company regime.

For management teams of Private equity-backed companies, the uncertainty about potential future tax increases will feed into discussions over how you should structure any management rollover. Key questions will include whether to provide for tax deferral of gains into new equity, or to crystalise in full and re-invest.

PE Houses are going to need to plan for uncertainty and be flexible in their thinking. We can leverage our expertise to help guide you through the journey, as well as offering management team support.

For help and advice on choosing the right structure for your next fund, please contact Jennifer Wall or James Pratt.