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FEATURING Appleby // BDO // Carey Olsen // Deutsche Bank // Guernsey Finance // Ogier
WEEKHFMS P E C I A L R E P O R T
AIFMD Both EU and non-EU funds are supported
FLEXIBILITY Business-friendly regulators seek to work with the industry
TAXATION Guernsey’s tax environment offers advantages
GUERNSEY 2015
applebyglobal.com
Intelligent and insightful offshore
OFFSHORE REACH
For more information, please contact:
Kate Storey
+44(0)1481 755 620
G U E R N S E Y 2 0 1 5
H F M W E E K . CO M 3
I N T R O D U C T I O N
REPORT EDITOR Drew Nicol T: +44 (0) 20 7832 6659 [email protected] HFMWEEK HEAD OF CONTENT Paul McMillan T: +44 (0) 20 7832 6622 [email protected] HEAD OF PRODUCTION Claudia Honerjager SENIOR SUB-EDITOR Eleanor Stanley SUB-EDITORS Luke Tuchscherer, Mary Cooch GROUP COMMERCIAL MANAGER Lucy Churchill T: +44 (0) 20 7832 6615 [email protected] SENIOR PUBLISHING ACCOUNT MANAGER Tara Nolan +44 (0) 20 7832 6612, [email protected] PUBLISHING ACCOUNT MANAGERS Amy Reed T: +44 (0) 20 7832 6618 [email protected]; Jack Duddy T: +44 (0) 20 7832 6613 [email protected]; Alex Roper T: +44 (0) 20 7832 6594 [email protected] CONTENT SALES Tel: +44 (0) 20 7832 6511 [email protected] CIRCULATION MANAGER Fay Muddle T: +44 (0) 20 7832 6524 [email protected] CEO Charlie Kerr
HFMWeek is published weekly by Pageant Media Ltd ISSN 1748-5894 Printed by The Manson Group © 2015 all rights reserved. No part of this publication may be reproduced or used without the prior permission from the publisher
Published by Pageant Media Ltd LONDONThird Floor, Thavies Inn House, 3-4 Holborn Circus, London, EC1N 2HAT +44 (0) 20 7832 6500 NEW YORK 240 W 37th Street , Suite 302, NY 10018 T +1 (212) 268 4919
HFMHED
GEF
UN
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AN
AGER
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uernsey is continuing to embrace its status as a Europe-based hedge fund domicile outside of the EU. The Guernsey regulatory body, the GFSC, has spent the last year busily touting the offshore domicile as an alternative for managers looking to market their funds both inside and outside of the EU and wanting to divide their regulatory requirements accordingly.
This proactive response to the introduction of the AIFMD has placed Guernsey in a strong position
to attract a large variety of funds thanks to its developed infrastructure and flexible regulatory regime. As a result, the island’s operators are showing an overwhelming confidence in the domicile’s recent growth continuing in 2015 and beyond.
In this latest HFM Guernsey Report 2015 we speak to Guernsey-based industry experts who explain the benefits of the various fund structures available in Guernsey as well as the multiple tax incentives it boasts compared to onshore ‘home’ jurisdictions. We also discuss how the island’s regulatory framework remains responsive to the evolving demands of the industry. The recent changes affecting US bank relationships with funds is testament to this commitment.
The report also analyses how the future challenges of the Beps project will affect Guernsey’s status as a premier offshore domicile as well as the potential opportunities for more fund structures being supported there.
Drew NicolREPORT EDITOR
GG U E R N S E Y 2 0 1 5
4 H F M W E E K . CO M
G U E R N S E Y 2 0 1 5 C O N T E N T S
LAW
NEW INTERNATIONAL TAX RULES – WHERE NOW FOR HEDGE FUNDS?Chris Hutley-Hurst, senior associate at Carey Olsen, Guernsey, highlights the key areas where the Beps project has potential to impact hedge funds and raises issues that hedge fund managers should be thinking about now
ACCOUNTING
INVESTING IN ILS THROUGH GUERNSEYRichard Searle of BDO discusses the ILS market in Guernsey and his expectations for future growth
LEGAL
TOTAL FLEXIBILITYOgier’s William Simpson and Val Rouse outline some of Guernsey’s fund structures and how the evolving regulatory landscape maintains Guernsey as a premier domicile
FINANCIAL SERVICES
REGULATORY PRESSURES HIT GUERNSEY FUNDS INDUSTRYSinéad Leddy, technical director at Guernsey Finance, examines how the current European landscape is affecting the funds sector in the Island
LAW
GUERNSEY’S CHOICE OF FUND STRUCTURESKate Storey examines the key features and benefits of the different structures in Guernsey and the factors that commonly influence the choice of structure
06
09
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here.
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BANKING FUNDS INSURANCE PRIVATE WEALTH
6 H F M W E E K . CO M
G U E R N S E Y 2 0 1 5
Current international tax rules are based on principles that have not kept up with globalisa-tion and the rise of the digital economy. Over the years the rules have been patched up but, almost two years ago, the Organisation for Economic Co-operation and Development
(OECD), acknowledging that a substantial overhaul was needed to combat base erosion and profi t shift ing (Beps), launched its ambitious 15-point ac-tion plan designed to re-write the rules for international taxation.
With the support of the G20 and many other countries, the OECD is working hard to meet the goals of its action plan, with the fi nal self-imposed deadline being this De-cember. Th is will give countries the domestic and international tools they need to eliminate double non-taxation of income and prevent tax minimisation strategies while con-tinuing to prevent double taxation.
On the face of it the initiative is aimed at multinationals but its reach will be far wider and will af-fect hedge funds whether they are based onshore or off shore.
THE KEY ISSUES ARE:Taxable nexusIn ascertaining whether a business has a taxable nexus in a particular country the current rules for businesses that are not resident in that country, generally look at whether the business has a physical presence or ‘permanent estab-lishment’ there. Such a presence can include an offi ce or agent but there are a number of exclusions to the concept so that, for example, a distribution warehouse, a server or a signifi cant customer base in a particular country are not typically enough on their own for a business to have a tax-able presence there.
Th is is set to change soon. Proposals coming out of the Beps project include extending the concept of permanent establishment to cover a number of other situations. In addition to capturing the physical presences that are not currently counted, the proposals also include the creation
of a ‘virtual permanent establishment’ in a country where a server is located or contracts are habitually concluded through technological means with persons located in that country. A new taxable nexus based on having a ‘signifi cant digital presence’ in a country is also proposed.
Hedge funds that use high frequency trading, particularly co-location, will need to keep an eye on these proposals as, for example, a taxable presence of the fund
could be created in a country where the fund’s server is located. Such funds will need to consider their digital infrastructure in prepa-ration for the implementation of these new rules.
Profi t allocationClosely tied to taxable nexus is profi t allocation which is the most complex area of the BEPS project and the one that is likely to take the longest to implement. It could also result in the most litigation because diff erent countries may well have diff erent views as to what or where the profi t allocation should be.
Th e ability to demonstrate sub-stance will be paramount but there are a number of other factors that will be relevant, including value creation, capital at risk, personnel
and physical presence. At the heart of profi t allocation is transfer pricing and
the OECD aims to change the rules around this to ensure that taxable profi ts are allocated to the jurisdiction where the value was created. Th e OECD is focusing on the fol-lowing three criteria:
1. Intangibles including ensuring that such profi ts are appropriately allocated in line with value creation, de-veloping transfer pricing rules for hard-to-value intan-gibles and updating guidance on cost-contribution arrangements
2. Risks and capital including allocating income on the basis of the location of business operations and dis-regarding related-party contractual and risk-shift ing arrangements
ON THE FACE OF IT THE INITIATIVE IS AIMED AT
MULTINATIONALS BUT ITS REACH WILL BE FAR WIDER AND WILL AFFECT HEDGE FUNDS WHETHER THEY
ARE BASED ONSHORE OR OFFSHORE
”
CHRIS HUTLEY-HURST, SENIOR ASSOCIATE AT CAREY OLSEN, GUERNSEY, HIGHLIGHTS THE KEY AREAS WHERE THE BEPS PROJECT HAS POTENTIAL TO IMPACT HEDGE FUNDS AND RAISES ISSUES THAT HEDGE FUND MANAGERS SHOULD BE THINKING ABOUT NOW
NEW INTERNATIONAL TAX RULES – WHERE NOW FOR
HEDGE FUNDS?
Chris Hutley-Hurst senior associate with Carey Olsen Guernsey acts for financial institutions, Guernsey businesses and leading law firms in London and elsewhere on corporate, private equity, fund and listing matters. As an experienced tax lawyer, he also advises on international fiscal matters, including the OECD’s project on Base Erosion and Profit Shifting and FATCA/CRS.
L A W
H F M W E E K . CO M 7
3. High-risk activities including re-characterising trans-actions that would not, or would only very rarely, oc-cur between third parties.
For high-frequency traders a number of factors will need to be taken into account such as the location of the programmers that create and maintain the algorithm, and the capital put at risk, which could make the allocation of profits a complex and costly task.
Treaty abuse Model treaty provisions dealing with limitation of bene-fits, a general anti-abuse rule and targeted anti-abuse rules have all been proposed to prevent the inappropriate use of double tax treaties to obtain relief such as the minimisa-tion of local withholding or capital gains tax.
This could affect illiquid investments in structures that rely on tax treaties to minimise the impact of taxes in the jurisdiction where the investment has been established. Both onshore and offshore structures could be affected because companies resident in tax treaty jurisdictions may be directly affected and holding companies resident in off-shore jurisdictions indirectly so.
THE FUTUREIt must be stressed that the OECD can only produce ‘soft law’ in the form of reports, recommendations, model legis-lation, model treaty provisions, guidance and a model mul-ti-national treaty. These are not backed by the weight of law and so countries will still need to take action to adopt them.
While some actions are likely to happen in the near fu-ture others are likely to take much longer and it is also rec-ognised that some proposals do not yet adequately address funds – meaning further work needs to be done.
There is broad political support for the Beps project but countries will need to harmonise their laws in certain areas for it to succeed. To prevent base erosion it must first be established which country’s tax base is being eroded and, where businesses are located over various countries, this is not an easy thing to establish. Therefore it is likely that some businesses will end up with more than one country laying claim to taxing rights over its profits.
It was the prevention of such double taxation that gave rise to the international tax rules we currently abide by. While the OECD firmly maintains the goal of preventing double taxation the focus of individual countries on elimi-nating double non-taxation could cause them to jump the gun and bring in domestic anti-BEPS legislation designed to protect their own domestic tax base, which would not be in step with the laws of other countries. The UK, for example, has recently implemented a ‘diverted profits tax’ – an extra-territorial tax that is aimed at contrived or arti-ficial arrangements used by large multinationals to erode its tax base. Crucially this new tax is designed not to be subject to the 100 plus double tax treaties that the UK has entered into.
If countries adopt an uncoordinated approach to protect their tax bases, especially in rules relating to taxable nexus and allocation of profits, then we could see more uncertain-ty in the application of international-focussed tax rules as well as an increase in associated litigation and overall costs. Australia has suggested that it will implement a diverted profits tax and, if other countries follow the UK’s lead, then existing double tax treaties could become less relevant and the risk of double taxation will increase significantly.
Businesses such as hedge funds may consider either in-creasing their presence in an offshore jurisdiction, such as Guernsey, or relocating offshore altogether. While such a move may not protect a business from anti-Beps laws en-tirely it can protect it from the uncertainty, and associated cost climbs, that could arise if rules are introduced in an un-coordinated manner.
THERE IS BROAD POLITICAL SUPPORT FOR THE BEPS PROJECT BUT COUNTRIES WILL NEED TO
HARMONISE THEIR LAWS IN CERTAIN AREAS FOR IT TO SUCCEED
”
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A C C O U N T I N G
H F M W E E K . CO M 9
G U E R N S E Y 2 0 1 5
HFMWeek (HFM): How has the global insurance-linked securities (ILS) market developed over the past 12 months? Richard Searle (RS): Th e global ILS market has devel-oped signifi cantly in recent years with 2014 showing a record breaking year with over $24.3bn on risk covering catastrophe bonds at 31 December 2014, according to the Aon Benfi eld fourth-quarter 2014 update. Strong investor demand has fed larger transactions across the market with coverage being extended into a variety of risks, some of which are outside the traditional catastro-phe bond market.
HFM: Will the changes announced in this year’s UK budget (allowing ILS to be domiciled in the UK) af-fect other jurisdictions in terms of competition and volumes of business? What can Guernsey off er that the UK can-not? RS: Th e timing of George Os-borne’s announcement on 18 March 2015 that the government will explicitly target ILS in a plan to grow the London insurance market was particularly interesting considering it fell on the same day that Guernsey Finance presented its ILS Insight London at the Brit-ish Museum. Th e general response to the announcement was that this reinforces recognition of the ILS market as an important piece of the fi nancial services jigsaw. One could take the view that London would be a new competitor to Guernsey in this particular sector though I see a broader welcoming of the announcement. Specifi cally, this demonstrates recognition of the maturity of this mar-ket and of ILS as an asset class that is now considered to be more mainstream than alternative.
Regarding other jurisdictions, there are clearly a num-ber of locations that have been off ering ILS products very successfully for many years. Any successful product is bound to att ract new entrants to the market and this is to be welcomed. In terms of the impact on Guernsey and what it can off er that the UK cannot, I think it is more ben-efi cial to focus on how Guernsey off ers solutions to the market as opposed to looking for unique selling points. Th e long history of innovative insurance, PCC and ICC
structures in Guernsey, supported by the mature fund, fi -duciary, accounting and legal industries means that there is a high concentration of extensive expertise in Guernsey operating under a stable regulatory environment, the size and experience of which means that Guernsey can re-spond rapidly to changes in the market place.
HFM: Th ere has been a growth in hedge funds launch-ing reinsurance arms. What do you think of this trend? RS: Th e growth in hedge funds launching reinsurance arms could be seen as a natural development in an indus-try that is always on the lookout for opportunities for its investors. A number of hedge funds have operated in this space for quite some time and the formalisation of this structuring through reinsurance arms again reinforces the att ractiveness of insurance products as part of an invest-
ment strategy. When considering yields across
certain asset classes in recent years it is easy to see why insurance would be an att ractive option, particularly given the lack of correlation be-tween insurance risk and the mar-ket risk that aff ects many other as-set classes. Nevertheless, there are clearly hurdles to be overcome for any fund managers considering a foray into the insurance market, not least being the regulatory environ-ments, costs and minimising man-agement’s distraction from the core business of the hedge fund.
One solution that we have seen working very well to this is where fund managers have invested into ILS products through existing ILS
structures, which are typically in cell company models such as Aon’s White Rock Insurance Company PCC Lim-ited, White Rock Insurance (Guernsey) ICC Limited and Robus Group’s Hexagon Insurance PCC. Th e advantage of such structures is that they allow investors to diversify their asset class risk whilst still giving them the reassurance that comes with a well regulated and governed structure in an established and stable environment, yet in a relatively low cost investment platform.
Cellular structures can operate with multiple investment managers investing into diff erent cells as in the aforemen-tioned models, or alternatively with a single investment manager invested into an entire PCC or ICC using multi-
RICHARD SEARLE, OF BDO, DISCUSSES THE ILS MARKET IN GUERNSEY AND HIS EXPECTATIONS FOR FUTURE GROWTH
INVESTING IN ILS THROUGH GUERNSEY
THERE IS A HIGH CONCENTRATION OF
EXTENSIVE EXPERTISE IN GUERNSEY
OPERATING UNDER A STABLE REGULATORY
ENVIRONMENT
”
Richard Searle has over 25 years of audit, assurance and advisory experience and has been audit partner on over 100 funds and insurance entities. His sector specialisms include real estate and private equity funds, ILS and Shariah-compliant insurance structuring.
A C C O U N T I N G
1 0 H F M W E E K . CO M
G U E R N S E Y 2 0 1 5
ple cells for different funds, as in the case with Secquaero Re (Guernsey) ICC Limited, managed by Aon Insurance Managers Guernsey. Both solutions have equally compel-ling arguments in their favour and the adoption of one or the other really depends on the specific circumstances of the individual manager, fund(s), and investor bases involved.
HFM: How does the ILS market in Guernsey compare to rival domiciles? RS: As mentioned before, there are a number of jurisdic-tions that offer ILS products and it would be difficult to select the unique selling point that can be used to claim dominance over all other domiciles. Similarly within each jurisdiction there will clearly be appropriate pairings be-tween ILS providers and their typical client base and geographies. I think Guernsey enjoys a concentration of core expertise with significant experience in insurance and investment management as well as accounting and legal experience. Furthermore, the nature of the fund and insur-ance industries in Guernsey has created a significant level of experience not just in locally-based structures but also in international financial services regulation and structur-ing. Finally, the regulatory environment has developed over the past three decades to evolve into a robust yet proportionate regulatory framework in which a key selling point for Guernsey is the speed of response and ease of access to the regulator.
HFM: In which direction do you predict cat bond yields will go over the next 12 to 18 months? RS: The prediction of cat bond yields is a complex matter which is far beyond my level of investment qualification!
That said, it is clear that cat bond yields have been falling in recent times as have reinsurance rates, and these may well be a simple effect of supply and demand. It is impor-tant that any investment manager continues to look not just at yields but also at the level of returns relative to the risks involved in the asset class and the diversity of the fund’s portfolio.
HFM: How do you see the ILS sector developing over the next five years in terms of investor interest? RS: The next five years promise to be an interesting and exciting time in the development of the ILS sector. The increasing level of awareness in recent years in this sector has created additional demand which has most likely had an effect on pricing. I think there will continue to be an expansion of ILS products into other risks in addition to the more traditional catastrophe bond products, and we have already seen this in the market with a Shariah-com-pliant listed bond accessing life assurance risk, and with longevity risk transfer products. There will also likely be an impact of technology and a greater move towards insur-ance products reporting in-line with investor demands. In fact we have already seen this with discussions around the reporting of daily NAVs on one ILS client to its investor funds. This will present an interesting balancing act be-tween investors’ desire to respond quickly to events and what is essentially an illiquid and long-term underlying asset class. In summary, the future looks exciting for the ILS sector with greater interest and investor appetite be-ing seen from funds and it is encouraging that Guernsey is very well placed to provide innovative solutions to meet investor needs.
L E G A L
H F M W E E K . CO M 11
G U E R N S E Y 2 0 1 5
HFMWeek (HFM): What are the diff erent fund types that have been set up in Guernsey?WILLIAM SIMPSON and VAL ROUSE (WS&VR):Guernsey, as an established off shore jurisdiction, contin-ues to be a popular home for all fund types, including many open-ended funds as well as for the administration of non-Guernsey funds. Guernsey’s closed-ended investment funds are currently a particular growth area in terms of recent set-ups and new enquiries. Examples of recent closed-ended fund structures advised on by Ogier include a fourth Guern-sey fund for Mid Europa investing in Central and Eastern Europe and Turkey, which closed at €800m, a London main market listed infrastructure fund for Sequoia raising £150m, and a fund raising $500m investing in a pan-African portfo-lio of private equity investments for Development Partners. Ogier is also seeing many more enquiries and has received instructions on various new funds for launch later this year, including debt funds and London main market listings.
HFM: What are the advantages of these fund structures?WS&VR: Guernsey has always of-fered a very fl exible open-ended funds’ regime, which lends itself to all types of fund structures, including hedge funds. Th e lack of restriction on investment parameters (other than a requirement for the spread of risk) means that many diff erent types of open ended funds may be quite easily established in Guernsey. Th ere is also fl exibility in the closed-ended fund regime. A Guernsey closed-ended investment fund may be either registered or authorised. Th e main diff erence can be found in the application process, where a lighter regulatory touch applies. A registered fund may nor-mally be established within a shorter overall timetable than an authorised fund.
HFM: Why have these funds found a home in Guernsey?WS&VR: Guernsey has modern and up-to-date legislation to govern corporate and limited partnership vehicles. Au-thorised and registered closed-ended funds established as Guernsey limited companies have proved very suitable for the UK listed market. Guernsey remains the preferred juris-diction, excluding the UK, for the listing of vehicles of the London Stock Exchange. Figures to the end of November 2014 show 119 Guernsey-incorporated entities listed on its various markets. A structure including one or more Guern-sey limited partnership is also well suited for private equity fund purposes. Guernsey licensed administrators have expe-
rience of and are well placed to administer general partner and carry vehicles associated with such structures. Ogier can also assist with licence applications and all Guernsey related matt ers.
HFM: How has the Guernsey regulatory system devel-oped to accommodate these fund structures?WS&VR: Th e existing fl exibility within the Guernsey regu-latory system means that a wide range of fund structures can be accommodated, without (unlike other jurisdictions) the need to amend legislation and/or design bespoke regimes. Th at said, the overall legal and regulatory framework remains under constant review and improvements continue to be made from time to time. For example, a recent change to the rules governing registered funds means that such schemes may now be off ered directly to the public in Guernsey. It is understood that this will assist with the Volcker Rule, which would appear to prevent US banking entities from sponsor-
ing, investing in or having certain relationships with a fund that could not be sold to investors in its home jurisdiction.
HFM: Has Guernsey’s non-EU stance played a part in which fund types it att racts?WS&VR: Guernsey took a very pro-active approach to the introduc-tion of the AIFMD. Th e marketing of Guernsey funds under national private placement regimes is gener-ally working well in most European countries. However, it must be re-membered that the AIFMD will not apply to all Guernsey funds. A Guern-
sey fund which is not marketed in the EU will fall outside of the Directive. Certain fund structures advised on by Ogier fall into this category. Conversely, Ogier works closely with EU onshore counsel in the case of Guernsey funds which are to be marketed in the EU and can advise on the application of the Guernsey AIFMD marketing rules.
HFM: Do you see new fund types being introduced in the future. If so, which ones and why?WS&VR: Possibly: Guernsey continues to keep its regula-tory regime under review. However, the existing regulatory regime remains fl exible enough both to permit innovative solutions and to accommodate a wide range of fund types.
Contact detailsFor further information, please contact either William Simpson, partner of Ogier on email [email protected] or Val Rouse, senior associate of Ogier on email [email protected] or Tel +44 1481 721672.
OGIER’S WILLIAM SIMPSON AND VAL ROUSE OUTLINE SOME OF GUERNSEY’S FUND STRUCTURES AND HOW THE EVOLVING REGULATORY LANDSCAPE MAINTAINS GUERNSEY AS A PREMIER DOMICILE
TOTAL FLEXIBILITY
GUERNSEY HAS MODERN AND UP TO DATE
LEGISLATION TO GOVERN CORPORATE AND LIMITED PARTNERSHIP VEHICLES
”
Val Rouse specialises in investment funds and regulatory matters and has extensive knowledge of the Guernsey investment fund regulatory regime having worked in the fund industry and at the Guernsey Financial Services Commission before becoming a Guernsey advocate.
William Simpson has more than 25 years’ offshore experience and has spent time in the Cayman Islands and the British Virgin Islands, before moving to Guernsey. He is a specialist investment funds lawyer and has advised on a broad range of investment structures for both corporate and private clients.
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HFMWeek charts the acrimonious
end for the innovative London-based
manager ANALYS IS 18
THE FALL OF
DECURAHEDGE FUND FIRMS based
anywhere in the world that raise
more than $500,000 in fees
from investors in California
are to be hit with a new tax
on this income, HFMWeek has
learned.
Either the management com-
pany or the owners of the man-
agement company, assuming it
is a partnership for US tax pur-
poses, would be subject to the
new tax, set to be introduced
next year but backdated to 1
January 2015.
The $500,000 limit test
will be calculated based on all
gross performance and man-
agement fee income gener-
ated from the investors in the
state of California. However,
the tax will be paid on net
income (gross revenue minus
expenses).
As an example, if the net
income of the management
company is $1m and included
in the gross income is more
than $500,000 in fees from
California-based investors, the
company would be subject to
the tax filing.
If 10% of the gross income is
from Californian investors then
$100,000 of the $1m would be
subject to 9% corporation tax.
If the management company
is owned 50/50 by two indi-
viduals, each owner
will have $50,000 of
Firms raising over $500,000 in
fees face up to 13% annual
levy
BY MAIYA KEIDAN
03
COMMENT PERCEPT ION VERSUS RE AL I T Y
14
Hedge funds
face new
California tax
INVESTOR
DEMANDS FOR
STANDARDISATION
THERE ARE PLENTY OF POSITIVES
FOR MANAGERS IN EMBRACING
VARIOUS INDUSTRY STANDARDS
ANALYSIS 16
The long and the short of it
ISSUE 371 12 March 2015
CLOSURE 10
$2.2BN TIGER CONSUMER MANAGEMENT TO SHUT DOORS
Patrick McCormack to return money by end-March
TAX 03
UK TAX AUTHORITY LAUNCHES LLP INVESTIGATION
Industry experts expect hedge funds to be examined
REDEMPTION 07
RHODE ISLAND TO OFFLOAD $19.6M BLUECREST HOLDING
Decision made on performance grounds after lacklustre period
s indd 1
10/03/2015 16
www.hfmweek .com
HFMWeek interviews Luke Ellis,
president of $72.9bn Man Group,
about growth opportunities and the
fi rm’s acquisition strategy
ANALYS IS 16
TO BUY OR TO BUILD?
$12BN MAGNETAR Capital
has launched a new credit fund
as a growing number of manag-
ers spot investment opportuni-
ties in the sector.The Chicago-based firm,
run by CEO Alec Litowitz,
launched the Magnetar Credit
Opportunities Fund earlier this
month with nearly $60m of
assets raised from seven initial
investors, HFMWeek has learned.
The news comes as Man
Group president Luke Ellis
revealed more details of its US
distressed credit plans, in an
interview with HFMWeek.
The $72.9bn London-based
alternatives giant recruited
distressed investment special-
ist and former Perry Capital
manager Himanshu Gulati last
month as head of US distressed
debt. Gulati said he believed
there were currently “signifi-
cant investment opportunities”
within the asset class.New York-based Gulati is
close to completing the hires
for a seven or eight person
team focused on building out
the firm’s distressed debt pres-
ence in the US, with Ellis telling
HFMWeek that Man hopes to
have a fund up and running by
the summer.Magnetar Capital was found-
ed in 2005 and invests in global
event-driven, fixed income and energy
Move comes as Man Group
reveals more on US distressed
debt plansBY ALEX CARDNO & JASMIN LEITNER
03
COMMENT HOPES FOR A BETTER EUROPEAN PROSPECTUS REGIME 14
Magnetar Capital latest to spot credit
opportunities
WHAT DOES THE WEAVERING VERDICT
MEAN?THE COURT OF APPEAL’S DECISION SURPRISED MOST
INDUSTRY OBSERVERSANALYSIS 19
The long and the short of it
ISSUE 372 19 March 2015
LAUNCH 10
BLUECREST TO OPEN $1BN FUND TO OUTSIDE INVESTORS
Michael Platt’s fi rm to open multi-strat equity fund next month
ASSET RAISING 05
OLD MUTUAL EYES BIG RAISE FOR FIXED INCOME STRATEGY
Six-strong team to run strat with heavy OTC derivatives tilt
PEOPLE MOVES 07
ASPECT CAPITAL’S COMMERCIAL CHIEF RETIRES
Wareham leaves after nearly 10 years at $5bn quant fi rm
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17/03/2015 16:40
www.hfmweek .com
HFMWeek examines concerns
that hedge funds could be the
unintended victims of global tax
clampdowns ANALYS IS 16
CAUGHT IN THE
TAX CROSSFIRE
A NUMBER OF large admin
firms are demanding reassur-
ances from SS&C over ser-
vice agreements following its
move to acquire software firm
Advent.
SS&C agreed in February
to acquire San Francisco-
headquartered Advent Software
in a deal worth $2.7bn. Advent
has more than 4,300 customers
and its popular Geneva offering
is used by many of SS&C’s rival
administrators as well as a large
number of hedge funds.
Rival admins are concerned
the SS&C acquisition of
Advent could result in prices
being raised, SS&C gaining an
advantage in terms of future
Advent technology develop-
ments and insufficient Chinese
walls between Advent’s servic-
es and the SS&C hedge fund
administration business.
HFMWeek has spoken to one
large administrator that has writ-
ten to the senior management
of SS&C and Advent to request
a new legal agreement over the
deal. A number of other admins
say they will be asking for assur-
ances that SS&C will continue
to invest and develop Advent
technology and build adequate
Chinese walls between the
admin and the software arms.
The admin CEO said: “We
have instructed our
legal representatives
Rivals pose questions over
pricing, development and
Chinese walls
BY SAM MACDONALD
03
COMMENT T H E A S I AN O P POR TUN I T Y FOR H EDGE FUNDS14
Admins seek
reassurances over
SS&C/Advent deal
CITI FALLOUT, PRICING
PRESSURES AND THE
ADMIN “OLIGOPOLY”
NEWS AND VIEWS FROM THE
LATEST HFMWEEK BREAKFAST
BRIEFING ANALYSIS 19
The long and the short of it
ISSUE 373 26 March 2015
LAUNCH 11
MAN NUMERIC LAUNCHES FIRST TWO UCITS FUNDS
Firm offers EM equity and market-neutral products
PEOPLE MOVES 03
CQS HIRES BREVAN PARTNER AS RESEARCH HEAD
Matthew James joins CQS following Ramin departure
ACTIVISTS 07
SEC CHAIR WHITE WARNS ON ‘INFLAMMATORY RHETORIC’
White says activist spats may harm firms and shareholders
24/03/2015
www.hfmweek .com
P OW E R
HFMWeek reveals who’s made this
year’s investor power 30 list
ANALYS IS 16
FORMER BREVAN Howard partner Chris Rokos has
named his new firm Rokos Capital Management and
revealed senior staff members.Rokos is listed as a direc-
tor of the recently incorpo-rated firm, which is expected
to be one of the year’s biggest hedge fund launches, along-
side Nicholas Howard and Andrea French, according to
Companies House records.Howard, a former Barclays
managing director, and French, previously a partner at Brevan
Howard, have both held roles
at Rokos’ family office, estab-lished in 2013, working as
CRO and COO, according to their respective LinkedIn
profiles.Rokos Capital submitted its
application for FCA authori-sation last week and is in the
process of sourcing its service providers for the $1bn-plus
fund, HFMWeek understands.Mary Bynum, an inves-
tor relations pro at Comac Capital, is also understood to
be joining the firm, while for-mer Goldman Sachs co-head
of Asia-Pacific macro trading, Stuart Riley, has also been
hired, according to reports.Exact details of Rokos
Capital’s strategy are not clear, but a global macro
focus seems likely,
Nicholas Howard and Andrea French listed as directors of
high-profile launch BY JASMIN LEITNER
03
C O M M E N T THE GROWING COST OF REGULATORY COLLABORATION 14
Ex-Brevan partner readies Rokos Capital for launch
TARGETING THE CROWN DEPENDENCIESWOULD LABOUR LEADER ED MILIBAND BE ABLE TO CARRY OUT HIS BLACKLISTING THREAT?ANALYSIS 21
The long and the short of it
ISSUE 374 2 April 2015
LAUNCH 10
DALLAS-BASED WARRINGTON LAUNCHES ONSHORE FUND
Options trader spins out of Morgan Stanley
PEOPLE MOVES 05
ALBOURNE CEO SIMON RUDDICK TO STEP DOWN
Partner John Claisse to take over from August
PEOPLE MOVES 06
PM FOR $450M ARMAJARO FUND STEPS DOWN
Oliver Denny to become lead manager from 1 April
001_003_HFM374_News1.indd 1
F I N A N C I A L S E R V I C E S
H F M W E E K . CO M 13
G U E R N S E Y 2 0 1 5
HFMWeek (HFM): What are the biggest issues facing not only Guernsey’s funds industry, but the funds sec-tor as a whole?Sinéad Leddy (SL): Without question it’s the regulation and legislation coming down the pipeline. Th is includes the US’s Foreign Account Tax Compliance Act (Fatca), measures from the Organisation of Economic Coopera-tion and Development (OECD), such as the Common Reporting Standard (CRS) and the Base Erosion and Profi t Shift ing (Beps) project, and the Markets in Finan-cial Instruments Directive (Mifi d) and Alternative Invest-ment Fund Managers Directive (AIFMD) from Europe.
It was this combination of new regulation and legisla-tion which prompted us to host a technical masterclass in London in January to demonstrate the progressive way in which Guernsey has responded to all these developments.
HFM: What were some of the key ‘take homes’ from that masterclass?SL: Th e AIFMD was the biggest debating point because despite the initial ‘deadline’ for full legislative transposi-tion of the AIFMD being back in July 2013, there has been a real inconsistency in approach from EU and EEA national regula-tors in how they are implementing it.
Th e transitional year ended on 22 July 2014 and a report from KPMG showed that at that time only 23 of the 31 EU and EEA member states had implemented full legislative transposition of the AIFMD.
As such, even European fund managers cannot distribute funds into some EU/EEA member states due to the inconsistency of ap-
proach between national regulators. In this climate, it is no wonder that non-EU fund managers believe that the AIFMD is too burdensome, with some, particularly the US market, citing it as creating ‘fortress Europe’ and there-fore choosing not to market funds into Europe.
HFM: What has been Guernsey’s solution to this un-certainty?SL: Guernsey is not in the EU (although it is in the Euro-pean time zone). A large proportion of business relates to the EU in some form yet we also have a substantial amount of funds business which originates outside of Europe.
As such, the island has introduced a dual regulatory re-gime so that it is possible to continue to distribute Guern-sey funds into both EU and non-EU countries: the exist-ing regime remains for those investors and managers not requiring an AIFMD fund, including those using EU Na-tional Private Placement (NPP) regimes and those mar-keting to non-EU investors; and there is an opt-in regime which is fully AIFMD-compliant.
Guernsey’s opt-in equivalent regime, which has been in place since January 2014, is appropriate for funds re-
quiring full AIFMD compliance. However, Guernsey’s position as a third country means our manag-ers and funds who want to access Europe continue to be able to use NPP regimes.
We continue to hear positive feedback from promoters and their advisers that Guernsey’s regulatory environment is straightforward and, more importantly, things can progress in a timely manner. Th e turn-around times in Guernsey are low compared with our competitor territories where delayed applica-
IN THIS CLIMATE, IT IS NO WONDER THAT NON-EU
FUND MANAGERS BELIEVE THAT THE AIFMD IS TOO
BURDENSOME
”
SINÉAD LEDDY, TECHNICAL DIRECTOR AT GUERNSEY FINANCE, EXAMINES HOW THE CURRENT EUROPEAN LANDSCAPE IS AFFECTING THE FUNDS SECTOR IN THE ISLAND
REGULATORY PRESSURES HIT GUERNSEY FUNDS INDUSTRY
Sinéad Leddy is technical director at Guernsey Finance, the promotional agency for the island’s finance industry.
F I N A N C I A L S E R V I C E S
1 4 H F M W E E K . CO M
G U E R N S E Y 2 0 1 5
tions can cause issues when bringing a new product to market.
HFM: There is much debate surrounding the future of NPP and third-country passporting. What are your thoughts?SL: Many managers have continued to use NPP re-gimes due to the reduced burden in comparison with the AIFMD and they are working well. Figures from the GFSC show that at the end of January 2015, 46 Guernsey AIFMs had used Guernsey’s NPP regime to market AIFs into 15 European countries. Indeed, it is understood that several Cayman Islands domiciled funds are being migrated to Guernsey to take advantage of the effective-ness of our route for distribution into EU countries using NPP regimes.
The statistics show that NPP from Guernsey is being used to target the key countries into which promoters wish to market. A fund typically markets in be-tween two to four countries and NPP is the ideal approach for this model.
The European Securities and Markets Author-ity (Esma) has been consulting on the current and future implementation of the AIFMD with regard to extending the passport to third countries and Guernsey has been closely involved in this process.
For those marketing into Europe, the NPP route will be favoured by many due to the depth and breadth of requirements that fund managers will have to satisfy under full AIFMD. Indeed, it is expected that full-blown AIFMD compliance will only be sought if there are particular commercial reasons to do so.
Guernsey’s attraction is that it can provide a Eu-ropean platform but one which is not actually in the EU and therefore can offer a variety of options.
For example, it makes commercial sense for a fund manager marketing almost exclusively to Europe to have a fully AIFMD compliant plat-form. However, this does not have to be based in a mainland European domicile and, indeed, it could be a Guernsey platform because the island has also introduced a fully equivalent, opt-in AIFMD route to market.
HFM: What should fund managers be wary of in the current climate?SL: Managers should look carefully at whether the pan-European passports being offered are relevant to their investor base given that it is likely to be increasingly geo-graphically diverse. European Directives – such as the AIFMD but also the Undertakings for Collective Invest-ment in Transferable Securities (Ucits) Directive – cater for European (retail) investors but add to compliance obligations and costs. As such, if you do not need Ucits/AIFMD or only need limited access to them for certain in-vestors, then it is possible to break the non-EU business away into a parallel or feeder structure for which AIFMD compliance would neither be required nor necessary.
Conversely, if a manager has a platform in a mainland European domicile then it will have to comply fully with the AIFMD even if there is a large proportion of non-EU
investors. European mainland platforms do not offer the ability to separate the reporting obligations away from
non-EU investors, as with a Guernsey platform. In addition, managers and funds with no connec-
tion to the EU continue to be able to use regulatory regimes which are completely free from the require-ments associated with the AIFMD and as such, will have significant operational and cost benefits. For example, Investec Asset Management recently re-domiciled a $1.2bn fund focused solely on non-EU investors from Ireland to Guernsey to take advan-tage of our dual regime response to the AIFMD.
HFM: What substance is Guernsey able to demonstrate and offer in a post-AIFMD world?SL: A huge advantage for us as a fund domicile is the existing standards we already employ regard-ing oversight and the substance which is already present in existing Guernsey domiciled structures. There are more than 50 fund managers, adminis-trators and custodians servicing assets valued at more than $300bn.
Guernsey already plays host to a number of major asset managers, such as Apax, BC Partners, Credit Suisse, Investec, JP Morgan, Man Group, Mid Europa, Permira and Terra Firma which all
have offices and staff in the island. There is a range of fund administrators too, from major international names such as Citco, Northern Trust and State Street to boutique, in-dependent operations, coupled with a significant pool of qualified non-executive directors who are experienced in providing management functions.
Quality of service is evidenced by the fact that Guernsey providers administer or manage nearly 250 open-ended funds which are domiciled in other jurisdictions, typically the Cayman Islands, where there may be local substance challenges.
Unlike many competitor jurisdictions, Guernsey also al-ready has well-established custody businesses. They are in-creasingly being complemented by administrators who are setting up depositary functions to service private equity and real estate clients new to the requirement for a depositary under the AIFMD. However, it should be noted that those taking advantage of NPP regimes are able to access a light-er touch regime for non-financial assets compared to that which would be required under the full blown AIFMD.
MANAGERS SHOULD LOOK CAREFULLY AT WHETHER
THE PAN-EUROPEAN PASSPORTS BEING
OFFERED ARE RELEVANT TO THEIR INVESTOR BASE GIVEN THAT IT IS LIKELY TO BE INCREASINGLY
GEOGRAPHICALLY DIVERSE
”
GUERNSEY FUND FORMATIONS – YEAR-ON-YEAR
0
30
60
90
120
150
201420132012
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L A W
H F M W E E K . CO M 17
G U E R N S E Y 2 0 1 5
Guernsey off ers a fl exible choice of business vehicles for structuring funds and associated management and special purpose vehicles. Th e types of investment vehicle most oft en encountered in Guernsey are closed ended or open ended companies and unit trusts and closed ended limited partnerships. Additionally, Guernsey recently introduced its form of limited liability partnership, which has already proved popular as a vehicle to house fund managers and general partners (including of non-Guernsey funds).
TYPES OF VEHICLE1. CompanyTh e Guernsey limited liability company provides investors with limited liability to the amount unpaid on their shares. It also has the major advantage of not being subject to any capital maintenance principle. Accordingly, there are no authorised share capital or minimum issued share capital requirements, and distributions can be made out of capi-tal subject only to satisfaction of the prescribed solvency test. Shares can be issued at par value, denominated in any convertible currency and with or without premium, or with no par value. Th ere may be multiple classes of shares with diff erent rights.
An alternative to having diff erent classes of shares in a standard non-cellular company is to use a Guernsey cell company – either a protected cell company (PCC) or
incorporated cell company (ICC). In such a company shares can be issued in separate cells to shareholders who may be diff erent for each cell and diff erent from the share-holders of the ‘core’ of the PCC or umbrella ICC. Crucial-ly, unlike for share classes in a non-cellular company, the assets and liabilities of each cell are legally segregated from those of the other cells and the core of the PCC/umbrella ICC. Th erefore a cell company lends itself well to guaran-teed or protected products.
Th e key diff erence between a PCC and an ICC is that, in an ICC, the cells are incorporated as separate companies in their own right, thus providing an extra layer of legal segre-gation of assets and liabilities.
Th ere are clear cost and time savings in using a cell com-pany rather than sett ing up multiple fund structures - add-ing a cell to a PCC will be cheaper than forming a brand new legal entity, and the regulatory application and annual fees for cells will be lower than for separate funds. Further, there are reduced operating costs for cell companies, in that there is one board of directors and administrator, and audit fees can be shared across the cells.
Cell companies can also be used as rent-a-cell platforms to white label to multiple investment advisers who each take a separate cell or cells for their separate fund(s). Th is is more cost eff ective for investment advisers than sett ing up a standalone fund structure and helps new investment
KATE STOREY EXAMINES THE KEY FEATURES AND BENEFITS OF THE DIFFERENT FUND STRUCTURESIN GUERNSEY AND THE FACTORS THAT COMMONLY INFLUENCE THE CHOICE OF STRUCTURE
GUERNSEY’S CHOICE OF FUND STRUCTURES
Kate Storey is a senior funds lawyer in the Guernsey office of Appleby. She has extensive experience in the establishment, listing and regulation of Guernsey investment funds of all asset classes, as well as fund finance and restructurings. She sits on the technical committee of the Guernsey Investment Fund Association.
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advisers build a track record in an already estab-lished investment vehicle.
The standard rate of Guernsey corporation tax is currently 0%; alternatively a Guernsey corpo-rate fund may apply for exempt status so that it is exempt from Guernsey tax other than in respect of Guernsey source income (excluding bank in-terest).
2. Unit trustA unit trust is not a legal entity but a trust ar-rangement whereby the trustee holds the fund assets on trust for the benefit of the investors who hold units in the unit trust. A unit trust is consti-tuted by a trust instrument entered into between the trustee and the manager of the fund, to which investors adhere upon subscribing for units. The trustee acts as custodian (having a custodian which is independent from the manager is a re-quirement for Guernsey open ended funds).
Guernsey unit trusts have been commonly used for real estate funds, hence the acronym ‘GPUT’ (Guernsey property unit trust), but are by no means confined to such use.
Neither the trustee nor the assets of a unit trust will be liable to Guernsey income tax on the unit trust’s income arising outside Guernsey (nor on Guernsey bank interest). In certain jurisdictions a unit trust may be treated as tax transparent for income and non-transparent for capital distributions.
3. Limited partnershipAgain, a limited partnership is not a legal entity separate from its partners and must act through and be managed by its general partner(s), of which there may be more than one, with different functions. Usually a Guernsey SPV is established to act as general partner, which again may be a company, limited partnership, or since May 2014, a limited liability partnership.
The limited partners have no liability for the debts of the partnership beyond the amount of their investment (pro-vided they do not participate in management), whereas the general partner has unlimited liability for the debts of the partnership. There is no limit on the number of limited partners. A limited partnership is generally treated as being tax transparent and is therefore an attractive structure for various tax planning purposes and particularly favoured for structuring private equity and venture capital investments.
4. Limited liability partnershipThe Guernsey limited liability partnership combines the most advantageous features of a partnership and a com-pany. This gives the flexibility of operation of a partner-ship with reduced regulation compared to a company, combined with the benefit of its being a body corporate that can contract in its own right, with limited liability for its members which is not lost by participation in manage-ment. This may be attractive for real estate joint ventures and other investment ‘clubs’ where investors want to take a more active role.
The LLP is transparent for Guernsey tax purposes. It has been used to act as general partner of a UK limited part-
WHICHEVER BUSINESS VEHICLE IS CHOSEN,
GUERNSEY DOES NOT IMPOSE ANY ADDITIONAL LAYER OF TAX ON FUNDS OR THEIR
INVESTORS. IN ADDITION TO INCOME TAX NEUTRALITY,
THERE IS NO CAPITAL GAINS TAX AND NO WITHHOLDING
TAX OR STAMP DUTY IS APPLICABLE
”
nership in light of the changes to the UK’s Part-nership Accounts Regulations, which impose certain accounting standards and public filing requirements. These requirements do not apply to English or Scottish limited partnerships which have an LLP as their general partner.
It has also been used to house an investment management firm, which is something we are likely to see much more of given Guernsey’s thriv-ing funds industry and in the wake of AIFMD, due to which many EU-based fund managers are looking to relocate their operations outside of the EU; the ability to migrate existing LLPs into Guernsey will be attractive in this regard.
FACTORS INFLUENCING CHOICE OF STRUCTUREThere are six main factors to consider:
1. Investment strategy Whether the fund is to be closed or open ended will be relevant. A limited partnership is not as suitable for open ended funds because it is rela-tively cumbersome to add and remove investors.
If a proposed fund has multiple strategies, or investments are to be staggered or participated in by different investors, then a cell company, using a separate cell for each strategy, vintage or group of investors, may be the most suitable.
2. Asset typeIlliquid assets are more suited to a closed ended structure, and in the private equity and property fields this will often mean that a limited partnership is chosen.
If the fund is to invest in a diverse range of assets then this could be achieved by using a cell company to segregate assets and associated liabilities by asset class or geography in separate cells.
3. Investor expectationInvestors in particular jurisdictions may be more familiar with one type of structure than another and there may be a preference according to the investor type; for example, in-stitutional investors will be familiar with investing through a limited partnership structure.
4. ListingIf it is intended that the fund will be listed then the most suitable structure will be a company. If a cell company is used it is possible to have listed and unlisted cells and have cells listed on different markets.
5. AIFMDA company has the option of being self-managed for AIFMD purposes.
6. Tax implicationsTax implications for investors in their home jurisdiction will generally be the determining factor. Whichever busi-ness vehicle is chosen, Guernsey does not impose any ad-ditional layer of tax on funds or their investors. In addition to income tax neutrality, there is no capital gains tax and no withholding tax or stamp duty is applicable.
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www.bdo.ggAudit | Tax | Advisory RICHARD SEARLE
+44 (0)1481 746 067 [email protected]
BDO audit more Guernsey ILS (Insurance Linked Securities) cells and structures than any other firm, offering investors access to alternative asset classes, not correlated to general financial markets.
Our experience across both the funds and insurance sectors positions us perfectly to help our clients bridge these specialisms for both listed and unlisted funds.
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