Offshore funds are becoming increasingly more complex from a structural perspective and investors much more sophisticated.  What is often of paramount importance is that the tax structuring is correct and the fund is operated to adhere with any tax planning which has been sought. At HOTCHKISS we can advise on the following matters. 

1) the wording of the tax section of offer documentation;

2) corporate residence;

3) international tax structuring to maximise return for investors; and

4) the application of the EU Savings Directive to fund managers and administrators.