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Discover thought leadership and legal insights by our legal experts from across CMS. In our Expert Guides, written by CMS lawyers from across the jurisdictions where we operate, we provide you with in-depth legal research and insights that can be read both online and offline. You can also find Law-Now articles with focused legal analysis, commentary and insights to help you anticipate future challenges and much more.



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Expertise
26/07/2024
On your radar | Issue 25
Key employment issues to be aware of internationally  
23/07/2024
CMS International Disputes Digest – 2024 Summer Edition
Welcome to the Summer 2024 edition of the International Disputes Digest, our bi-annual publication exploring the latest trends and solutions to the challenges facing global business. Those challenges include the continuing war against Ukraine and in the Middle East, in addition to others such as climate change and Artificial Intelligence. In this edition, our experts in Brazil explain the impact of AI on resolving disputes and why robots will not replace arbitrators anytime soon. Separately, our colleagues in the Netherlands describe how Dutch litigation is leading the way in making both governments and companies accountable for policies resulting in climate damage, and how this litigious trend is defending biodiversity. The case of the Sultan of Sulu and how the passage of time in arbitration agreements might affect the integrity of an arbitration clause is the topic of analysis by our experts in Paris. We also consider the envisaged changes to the 7th edition of the SIAC Rules, a hot off the press analysis of the recently published 2024 IBA Guidelines on Conflict of Interest in International Arbitration, and our 2024 UK Banking Disputes Report, amongst other topics. We hope that you will enjoy reading these articles and please do contact the authors if you have queries in relation to them.
12/07/2024
Unregulated special limited partnership (“SCSp”) in Luxembourg
Published on July 12, 2024This Back to Basics note follows our key concepts briefings, which intend to provide high-level insights regarding funds fundamentals, funds vehicles and operational considerations, available here. What is a SCSp? The Luxembourg special limited partnership (société en commandite spéciale – SCSp) is a fund structure introduced in 2013 following the adoption of the law of 12 July 2013 on alternative investment fund managers (the AIFM Law). The SCSp differs from the common limited partnership (société en commandite simple - SCS) notably by the fact that it does not have legal personality. SCSps are subject to the law of 10 august 1915 on commercial compagnies (the 1915 Law) and to the AIFM Law to the extent that it qualifies as an alternative investment fund (AIF). It can in addition be subject to a product regime when used for a regulated fund vehicle (Part II UCI, SIF, SICAR or RAIF). Key features Eligible investors:There is no restriction on eligible investors for unregulated SCSps. Eligible assets:There is no restriction on eligible assets for an unregulated SCSp. Struc­tur­a­tion:SC­Sps are open or closed entities. They can only be formed as a single fund (umbrella structure not available). Set up:An SCSp is formed, for a limited or unlimited duration, by one or more partners with unlimited and joint and several liability for all the obligations of the partnership, and one or more limited partners who only contribute a specific amount constituting partnership interests which may but need not be represented by instruments, as provided in the partnership agreement. The fund is set up by means of a limited partnership agreement which can be made by private or public deed and offers a large flexibility on the set up. All Luxembourg SCSps must maintain a register of the partners. This register must be accessible to any partner, unless the limited partnership agreement disposes otherwise. Capital re­quire­ments:There is no minimum capital requirement for SCSps. Liability of partners:General partners (associés commandités) have unlimited joint and several liability for the obligations of the SCSp, whereas limited partners (associés commanditaires) are only liable up to the amount of their respective contributions or commitments. Limited partners are prohibited from carrying out any act of management vis-à-vis third parties. The general partner may act both as general partner (associé commandité) and manager (gérant) of the SCSp, hence being considered as managing general partner (associé commandité - gérant) and therefore also being held liable in its capacity as manager. Di­ver­si­fic­a­tion:There are no diversification requirements for unregulated SCSps. Marketing:An SCSp only benefits from the European marketing passport to the extent that it falls under the scope of the full regime of the alternative investment fund managers directive (AIFMD). Service providers: To the extent that the SCSp qualifies as an AIF that is not self-managed and above the AIFMD threshold, the following service providers are required:an authorised AIFM;a depositary having its registered office in Luxembourg or a branch in Luxembourg (if its registered office is in another Member State of the European Union), to ensure the safe keeping of its assets;an authorised independent auditor with appropriate professional experience to audit the annual report;a central administrator which is located in Luxembourg;a portfolio manager in case of delegation by the AIFM. Tax regime: An SCSp is tax transparent for corporate income tax and net wealth tax purposes. An SCSp qualifying as AIF is not subject to municipal business tax since it is not a business enterprise carrying out a commercial activity. The SCSp will however be deemed to be a business enterprise if its general partner is a capital company holding 5% or more of its partnership interests. Distributions made by an SCSp are not subject to Luxembourg withholding tax. An SCSp is generally not entitled to double tax treaties concluded by Luxembourg. The VAT status of an SCSp will depend on the activities performed. Main advantages of an SCSp:The main advantages for choosing the SCSp are, inter alia, that:it is internationally recognised and resembles the Anglo-Saxon limited partnership structures;it offers a high level of contractual flexibility and most of the rules can be freely determined in the partnership agreement, as there are very few compulsory provisions in the 1915 Law;it can be easily and rapidly set up and is subject to very limited registration formalities, allowing short time to market;it is not subject to CSSF authorisation or prudential supervision;it is tax transparent from a corporate and tax perspective;it offers confidentiality, as the information published on the Luxembourg Trade and Companies Register is limited to key provisions and does not include the identity of the limited partners nor their contributions; andit is not subject to any minimum capital requirement or minimum investment amount.
12/07/2024
The reserved alternative investment fund (“RAIF”) in Luxembourg - UPDATED
Updated on July 12, 2024This Back to Basics note follows our key concepts briefings, which intend to provide high-level insights regarding funds fundamentals, funds vehicles and operational considerations, available here. What is a RAIF? Luxembourg introduced the RAIF by a law of 23 July 2016 (the RAIF Law). RAIFs are also subject to the law of 12 July 2013 on Alternative Investment Fund Managers (the AIFM Law). RAIFs are considered as semi-regulated funds because they are not subject to the supervision of the Commission de Surveillance du Secteur Financier (CSSF), the Luxembourg supervisory authority but still involve the nomination of a duly authorised alternative investment fund manager (AIFM) subject to the AIFM Law. The RAIF regime aims at introducing a model with a less sophisticated process than regulated funds, without a double supervision by the CSSF, which make it more attractive for investment funds and asset management. The Luxembourg regime aligns with the European Union (EU)’s approach, through the Directive on AIFMs (the AIFMD), to focus on management supervision rather than product supervision. Key features Eligible investors:RAIFs are reserved for “well-informed investors”, who are:In­sti­tu­tion­al and professional investors (within the meaning Annex II to Directive 2014/65/EU); or Other investors who have stated in writing that they adhere to the status of well-informed investor and, either (i) invest a minimum of 100,000 Euros in the RAIF or (ii) have been the subject of an assessment made by a credit institution, an investment firm or a UCITS management company or an authorised AIFM certifying their expertise, experience and knowledge to adequately appraise the contemplated investment in the RAIF. Eligible assets:There is no restriction on the eligible assets. A RAIF may state in its constitutive documents that its exclusive purpose is to invest in risk capital, in which case the portfolio is limited to investments in risk cap­it­al. Cor­por­ate form and struc­tur­a­tion:RAIFs are open or closed entities which take the form of:Fonds commun de placement (FCP) or common contractual fund, which is a fund without legal personality managed by a Luxembourg management company; orSociété d’In­ves­t­isse­ment à Capital Variable (SICAV) or investment company with variable capital, in the form of a corporate entity (e.g. SA, SCA, Sàrl) or of a partnership with or without legal personality (SCS or SCSp). RAIF can be formed as a single fund or as an umbrella structure with an unlimited number of ring-fenced sub-funds. Each sub-fund can have its own investment policy, specific features, governing rules or investment manager. Set up:The RAIF may be set up as a partnership, a corporate company or an FCP further to the establishment or incorporation process of such entity (e.g. execution of a LPA, management regulations or incorporation of the company in front of a Luxembourg notary). The RAIF must establish an offering document which includes the information necessary for investors to be able to make an informed assessment of the investment and related risks. The service agreements of the mandatory RAIF’s service providers (as set out below) must be effective as of the date of its establishment / incorporation. The RAIF must be registered on the official list of RAIFs held with the Luxembourg trade and companies register. Capital requirements:The net assets of a RAIF may not be less than EUR 1,250,000, which must be reached within a period of twenty-four months following the entry into force of the management regulations of the FCP or from the incorporation of the SICAV. Only 5% of the capital must be paid up on subscription. Di­ver­si­fic­a­tion:RAIFs are subject to an obligation of diversification. The RAIF Law does not impose diversification rules. In practice, a limitation of 30% of the RAIF gross assets in any single investment is generally applied. RAIFs may benefit from an initial ramp-up period to comply with the above risk-spreading rules. These above diversification requirements do not apply to RAIFs investing solely in “risk capital” investments. Marketing:RAIFs benefit from the European marketing passport provided by the AIFMD to market shares, units or partnership interests across the European Economic Area. Service providers:RAIFs must appoint several service providers, the main ones being as follows:an authorised AIFM. RAIFs cannot be internally managed;a depositary having its registered office in Luxembourg or a branch in Luxembourg (if its registered office is in another Member State of the European Union), to ensure the safe keeping of its assets;an authorised independent auditor with appropriate professional experience which must audit the annual report; a central administrator whose head office must be located in Luxembourg; and a portfolio manager in case of delegation by the AIFM. Tax regime: Default RegimeRAIFs are not subject to corporate income tax, municipal business tax or net wealth tax but are subject to an annual subscription tax of 0.01% on their net assets (calculated and payable on a quarterly basis). Some exemptions from subscription tax apply depending on the investment assets (e.g., assets invested in other Luxembourg UCIs subject to this subscription tax, investment in microfinance institutions and pension fund pooling vehicles). Distributions made by RAIFs are not subject to withholding tax. RAIFs established under a corporate form may benefit from some tax treaties concluded by Luxembourg. RAIF investing in risk capitalThis regime is similar to the SICAR regime. RAIF under a corporate form will be subject to corporate income tax and municipal business tax at the aggregate rate of 24,94% (for Luxembourg-city in 2023) with an exemption available for income and gains derived from (i) transferable securities representing investments in risk capital and (ii) income arising from funds held pending their investment in risk capital (only applicable for a maximum period of twelve months preceding their investment in risk capital and where it can be established that the funds have effectively been invested in risk capital). RAIFs will be exempt from Luxembourg net wealth tax except for the minimum net wealth tax. Dis­tri­bu­tions made by RAIFs are not subject to withholding tax in Lux­em­bourg. RAIFs should have access to the double tax treaties concluded by Lux­em­bourg.  RAIFs under a partnership form are tax transparent and are not subject to corporate income tax, municipal business tax and net wealth tax. Distributions made by RAIFs are not subject to withholding tax. RAIFs should not be entitled to the double tax treaties concluded by Lux­em­bourg. RAIFs under a corporate form are subject to 20% real estate tax on rental income and capital gains realized upon disposal of Luxembourg real estate assets and disposal of interests or units in Luxembourg tax transparent entities or mutual funds holding Luxembourg real estate as­sets. Man­age­ment services rendered to RAIFs are exempt from VAT. Investment management services provided to RAIFs are exempt from VAT.   In Brief:
12/07/2024
Specialised investment fund (“SIF”) in Luxembourg
Published on July 12, 2024This Back to Basics note follows our key concepts briefings, which intend to provide high-level insights regarding funds fundamentals, funds vehicles and operational considerations, available here. What is a SIF? The SIF is an investment fund that can invest in all types of assets as permitted under the law of 13 February 2007 (the SIF Law). Following the law of 12 July 2013 on alternative investment fund managers (the AIFM Law), the SIF Law was divided in two parts, with provisions concerning general provisions applicable to all SIFs (Part I of the SIF Law) and specific provisions for SIFs that qualify as alternative investment funds (AIFs) (Part II of the SIF Law). SIFs are funds that are regulated and subject to the prudential supervision of the Commission de Surveillance du Secteur Financier (CSSF), the Luxembourg supervisory authority. SIFs must be authorised by the CSSF before commencing their activity and are supervised by the CSSF on an ongoing basis. Key features Eligible investors:SIFs are reserved for “well informed investors”, who are:In­sti­tu­tion­al and professional investors (within the meaning Annex II to Directive 2014/65/EU); or Other investors which have stated in writing that they adhere to the status of well-informed investor and, either (i) invest a minimum of 100,000 Euros in the SIF or (ii) have been the subject of an assessment made by a credit institution, an investment firm or a UCITS management company or an authorised alternative investment fund manager (AIFM) certifying their expertise, experience and knowledge to adequately appraise the contemplated investment in the SIF. Eligible assets:There is no restriction on eligible assets for SIFs. Corporate form and structuration of a SIF:SIFs are open or closed entities which take the form of:Fonds commun de placement (FCP) or common contractual fund, which is a fund without legal personality managed by a Luxembourg management company. Société d’In­ves­t­isse­ment à Capital Variable (SICAV) or investment company with variable capital, in the form of a corporate entity (e.g. SA, SCA, Sàrl) or of a partnership with or without legal personality (SCS or SCSp). SIFs can be formed as single funds or as umbrella structures with an unlimited number of ring-fenced sub-funds. Each sub-fund can have its own investment policy, specific features, governing rules or investment manager. Set up:The SIF may be set up as a partnership, a corporate company or an FCP further to the establishment or incorporation process of such entity (e.g. execution of a LPA, management regulations or incorporation of the company in front of a Luxembourg notary). The SIF must establish an offering document which includes the information necessary for investors to be able to make an informed assessment of the investment and related risks. The service agreements of the mandatory SIF’s service providers (as set out below) must be effective as of the date of its establishment / incorporation.A SIF must be approved by the CSSF and is under its permanent supervision through monthly and annual reporting. The approval triggers the entry of the SIF on the official list of SIFs held by the CSSF. Capital requirements:The net assets of a SIF may not be less than EUR 1,250,000, which must be reached within a period of twenty-four months following the authorisation of the SIF. Only 5% of the capital must be paid up on sub­scrip­tion. Di­ver­si­fic­a­tion:A SIF cannot invest more than 30 % of its assets in securities of the same nature issued by the same issuer. Diversification rules do not apply to:Investments in securities issued or guaranteed by an OECD Member State or its regional or local authorities or by EU, regional or global supranational institutions and bodies; andInvestments in target UCIs that are subject to risk-spreading requirements at least comparable to those applicable to SIFs. SIFs may benefit from an initial ramp-up period to comply with the above risk-spreading rules. Marketing:A SIF only benefits from the European marketing passport to the extent that it falls under the scope of the full regime of the alternative investment fund managers directive (AIFMD). Service providers:SIFs must appoint several service providers, the main ones being as follows:a SIF qualifying as an AIF that is not self-managed and above the AIFMD threshold is required to appoint an authorised AIFM;a depositary having its registered office in Luxembourg or a branch in Luxembourg (if its registered office is in another Member State of the European Union) to ensure the safe keeping of its assets;an authorised independent auditor with appropriate professional experience must audit the annual report; anda central administrator which is located in Luxembourg;a portfolio manager in case of delegation by the AIFM. Tax regime:SIFs are not subject to Luxembourg corporate income tax, municipal business tax and net wealth tax but are subject to an annual subscription tax of 0.01 % on their net assets (calculated and payable on a quarterly basis). Some exemptions from subscription tax apply depending on the investment assets (e.g., assets invested in other Luxembourg UCIs subject to this subscription tax, investment in microfinance institutions and pension fund pooling vehicles). SIFs under the form of a corporate entity are subject to 20% real estate tax on rental income and capital gains realized upon disposal of Luxembourg real estate assets and disposal of interests or units in Luxembourg tax transparent entities or mutual funds holding Luxembourg real estate assets. Distributions made by SIFs are not subject to withholding tax. SIFs established under the form of a corporate entity may benefit from some tax treaties concluded by Luxembourg. Management services rendered to SIFs are exempt from VAT. In brief
12/07/2024
Specialised investment fund (“SIF”) in Luxembourg
Published on July 12, 2024This Back to Basics note follows our key concepts briefings, which intend to provide high-level insights regarding funds fundamentals, funds vehicles and operational considerations, available here. What is a SIF? The SIF is an investment fund that can invest in all types of assets as permitted under the law of 13 February 2007 (the SIF Law). Following the law of 12 July 2013 on alternative investment fund managers (the AIFM Law), the SIF Law was divided in two parts, with provisions concerning general provisions applicable to all SIFs (Part I of the SIF Law) and specific provisions for SIFs that qualify as alternative investment funds (AIFs) (Part II of the SIF Law). SIFs are funds that are regulated and subject to the prudential supervision of the Commission de Surveillance du Secteur Financier (CSSF), the Luxembourg supervisory authority. SIFs must be authorised by the CSSF before commencing their activity and are supervised by the CSSF on an ongoing basis. Key features Eligible investors:SIFs are reserved for “well informed investors”, who are:In­sti­tu­tion­al and professional investors (within the meaning Annex II to Directive 2014/65/EU); or Other investors which have stated in writing that they adhere to the status of well-informed investor and, either (i) invest a minimum of 100,000 Euros in the SIF or (ii) have been the subject of an assessment made by a credit institution, an investment firm or a UCITS management company or an authorised alternative investment fund manager (AIFM) certifying their expertise, experience and knowledge to adequately appraise the contemplated investment in the SIF. Eligible assets:There is no restriction on eligible assets for SIFs. Corporate form and structuration of a SIF:SIFs are open or closed entities which take the form of:Fonds commun de placement (FCP) or common contractual fund, which is a fund without legal personality managed by a Luxembourg management company. Société d’In­ves­t­isse­ment à Capital Variable (SICAV) or investment company with variable capital, in the form of a corporate entity (e.g. SA, SCA, Sàrl) or of a partnership with or without legal personality (SCS or SCSp). SIFs can be formed as single funds or as umbrella structures with an unlimited number of ring-fenced sub-funds. Each sub-fund can have its own investment policy, specific features, governing rules or investment manager. Set up:The SIF may be set up as a partnership, a corporate company or an FCP further to the establishment or incorporation process of such entity (e.g. execution of a LPA, management regulations or incorporation of the company in front of a Luxembourg notary). The SIF must establish an offering document which includes the information necessary for investors to be able to make an informed assessment of the investment and related risks. The service agreements of the mandatory SIF’s service providers (as set out below) must be effective as of the date of its establishment / incorporation.A SIF must be approved by the CSSF and is under its permanent supervision through monthly and annual reporting. The approval triggers the entry of the SIF on the official list of SIFs held by the CSSF. Capital requirements:The net assets of a SIF may not be less than EUR 1,250,000, which must be reached within a period of twenty-four months following the authorisation of the SIF. Only 5% of the capital must be paid up on sub­scrip­tion. Di­ver­si­fic­a­tion:A SIF cannot invest more than 30 % of its assets in securities of the same nature issued by the same issuer. Diversification rules do not apply to:Investments in securities issued or guaranteed by an OECD Member State or its regional or local authorities or by EU, regional or global supranational institutions and bodies; andInvestments in target UCIs that are subject to risk-spreading requirements at least comparable to those applicable to SIFs. SIFs may benefit from an initial ramp-up period to comply with the above risk-spreading rules. Marketing:A SIF only benefits from the European marketing passport to the extent that it falls under the scope of the full regime of the alternative investment fund managers directive (AIFMD). Service providers:SIFs must appoint several service providers, the main ones being as follows:a SIF qualifying as an AIF that is not self-managed and above the AIFMD threshold is required to appoint an authorised AIFM;a depositary having its registered office in Luxembourg or a branch in Luxembourg (if its registered office is in another Member State of the European Union) to ensure the safe keeping of its assets;an authorised independent auditor with appropriate professional experience must audit the annual report; anda central administrator which is located in Luxembourg;a portfolio manager in case of delegation by the AIFM. Tax regime:SIFs are not subject to Luxembourg corporate income tax, municipal business tax and net wealth tax but are subject to an annual subscription tax of 0.01 % on their net assets (calculated and payable on a quarterly basis). Some exemptions from subscription tax apply depending on the investment assets (e.g., assets invested in other Luxembourg UCIs subject to this subscription tax, investment in microfinance institutions and pension fund pooling vehicles). SIFs under the form of a corporate entity are subject to 20% real estate tax on rental income and capital gains realized upon disposal of Luxembourg real estate assets and disposal of interests or units in Luxembourg tax transparent entities or mutual funds holding Luxembourg real estate assets. Distributions made by SIFs are not subject to withholding tax. SIFs established under the form of a corporate entity may benefit from some tax treaties concluded by Luxembourg. Management services rendered to SIFs are exempt from VAT. In brief
11/07/2024
Annual Review of Singapore Construction Law Developments
We are pleased to announce the publication of the 2023 edition of our Annual Review of Singapore Construction Law Developments. Now in its third year, the Annual Review summarises key developments in Singapore law that would be of relevance and have an impact on projects governed by Singapore law, over the previous calendar year. The publication has been prepared with our international clients in mind and aims to provide a greater degree of background and analysis than our regular Law-Now alert service. This year’s edition includes articles on the formation and the interpretation of contracts, and non-assignment clauses which are prevalent in standard form construction contracts. We also report on developments in relation to the adjudication, arbitration and dispute resolution regime in Singapore which are important topics in the construction industry. You can download a PDF version of the 2023 annual review below at the bottom of the page. Previous annual reviews are included below:Annual Review of Singapore Construction Law Developments 2022Annual Review of Singapore Construction Law Developments 2021
27/06/2024
AI and Funds
This Back to Basics note follows our key concepts briefings, which intend to provide high-level insights regarding funds fundamentals, funds vehicles and operational considerations, available here. Digital innovation is advancing and evolving at a fast pace for investment funds with artificial intelligence (AI) being a particularly high-profile topic.  Managers and investors are increasingly looking ahead to how technology can be applied to their activities and operations. In this briefing we give an insight into AI and how ethics, law and regulation are evolving. The recently approved EU Regulation laying down harmonised rules on artificial intelligence (the “EU AI Act") being one example discussed further below. The legal and regulatory backdrop is evolving from international and other ethical or similar principles. The EU AI Act will be legally binding for those within its scope and can include persons outside the EU. Fund managers and investors will need to consider how they use AI, the steps they take to ensure it is used correctly and have suitable governance procedures.
23/05/2024
Back to Basics briefings - New briefing added!
CMS Funds Group Back to Basics briefings intend to provide high level insights regarding funds fundamentals, funds vehicles and operational considerations New briefings are published on a regular basis, covering a specific jurisdiction or topic, and providing basic essential technical explanations.
23/05/2024
Back to Basics briefings - New briefing added!
CMS Funds Group Back to Basics briefings intend to provide high level insights regarding funds fundamentals, funds vehicles and operational considerations New briefings are published on a regular basis, covering a specific jurisdiction or topic, and providing basic essential technical explanations.
23/05/2024
Funds And Waterfall Structures
This briefing focuses on the use of distribution waterfalls and carried interest structures in funds. It covers:What is carried interest?What is a distribution waterfall?How does a basic waterfall operate?Hurdle ratesCatch upWhole-fund v deal-by-deal­Hy­brid waterfall struc­turesO­pen-ended fundsESG-linked carried interestFirst loss mechanisms What is carried interest? “Carried interest” is a form of per­form­ance-re­lated remuneration, where a fund sponsor or manager is rewarded with a share of fund profits where the fund has outperformed certain performance targets (often referred to as “hurdles”). In order for the sponsor to become entitled to a carried interest, the fund must typically first have provided the investors with a return of their capital invested, plus a return on that capital of an amount equal to the hurdle. As a form of profit share, a carried interest differs from a performance fee, which is often calculated in a similar manner but which is paid to the sponsor as a fee for provision of services (and which may therefore attract VAT and be taxed as income in the hands of the sponsor). In contrast, as of the date of publication of this briefing, carried interest should, if structured correctly and for UK tax purposes, be capable of being treated as a capital (rather than income) return in the hands of UK tax resident individual carried interest holders. For this reason, carried interest has historically been greatly favoured by fund managers as an effective and efficient means of incentivising (and retaining) management team members and providing per­form­ance-driv­en alignment of interest with investors. What is a distribution waterfall? A “distribution waterfall” refers to the ‘cascading’ order of priority by which net profits (income profits and capital gain) are distributed between the investors and sponsor of a fund. The structure of a waterfall will often vary depending on various factors, including the investment strategy, legal form and geography of the fund. This note refers to the use of carried interest and waterfall structures in the context of private funds, but it should be noted that similar mechanisms are often employed in other investment structures outside of funds, such as joint ventures, clubs, co-investments and segregated mandates. How does a basic waterfall operate? The structure and operation of the waterfall will typically be set out in the main fund agreement (such as a limited partnership agreement). In its most basic form, a waterfall might have the following sequential tiers: Hurdle rates The hurdle rate is typically expressed as a specified percentage internal rate of return (“IRR”) on the investors’ invested capital. The hurdle rate may vary depending on the investment strategy and targeted returns of the fund. Strategies which target higher returns typically with higher accompanying risks (such as value-add or opportunistic funds) may adopt a higher hurdle rate than strategies with lower return targets and/or risk profiles. However many private funds investing into alternatives will employ a base hurdle rate of between 7% to 9% IRR. Occasionally, other forms of hurdle may be adopted, such as a specified investment multiple on investors’ invested equity, either instead of or in conjunction with an IRR based hurdle. Other fund waterfalls have adopted tiered hurdle structures with differing carried interest sharing ratios. For example, the sponsor might receive a carried interest equal to 20% of profits over a first hurdle of 8% IRR, increasing to 25% of profits over a second hurdle of 12% IRR. Certain investors have however viewed such arrangements with caution, on the basis it can incentivise the management team to take increased risks in executing investment decisions. Finally, some funds have adopted “floating hurdles”, where the hurdle rate can vary from time to time. Such arrangements are not widespread but can be seen, for example, in private debt funds where the underlying loan investments may be originated at floating interest rates and investment returns will therefore vary accordingly over time. Catch up A catch up mechanism operates to provide the sponsor with an accelerated share of profits with the aim of ensuring the sponsor receives a specified percentage of the total fund profits. Typically, the catch up will apply between tiers 3 and 4 in the above waterfall example, and will apply to “catch up” the sponsor’s share of profits to its specified carried interest sharing percentage. For instance, in the example waterfall shown above, while the sponsor will receive, as a carried interest, 20% of profits above the hurdle, it will not have received 20% of total profits, as investors have already received the preferred return before any distribution of carried interest is made. A catch up might seek to rectify this by providing the sponsor with 100% of profits until it has received 20% of total profit distributions (i.e. excluding return of capital). Only once the sponsor has caught up to that 20% share would distributions then revert to the 80% / 20% split. In practice, the rate at which the sponsor is caught up (if at all) will vary depending on the fund strategy and the bargaining power of the stakeholders. While 100% rates of catch up are not uncommon in certain private equity and venture capital funds, we often see variations and in a private real estate context it is more commonly 50% / 50%. Whole fund vs deal-by-deal There are two main types of waterfall structures: “whole-fund” and “deal-by-deal”. They are often known as “European-style” (whole-fund) and “Amer­ic­an-style” (deal-by-deal), by reference to the locations where they had traditionally been pre-eminent. However those geographic distinctions have over the years become increasingly blurred. Whole Fund: Under the whole fund model, the waterfall is applied cumulatively in respect of contributions to, and distributions from, all investments made by the fund. This is generally seen as more favourable to investors, as the sponsor will not participate in carried interest until the investors have received a return of their invested capital plus the preferred return across all investments. This would typically not occur until the late-stage disposals made by the fund (i.e. the sponsor’s carried interest entitlements are back-ended until the end of the fund’s life). Deal-by-deal: Under the deal-by-deal model, the waterfall is applied separately in respect of each investment. This structure generally favours the sponsor, who may (subject to performance of individual investments) become entitled to carried interest, irrespective of the profitability (or losses) made on other investments. Due to this risk, investors into funds adopting the deal-by-deal model will often expect greater protection in the form of escrow, clawback or guarantees in order to mitigate the risk of carried interest overpayments to the sponsor (had the carried interest been calculated on a whole-fund basis). Hybrid waterfall structures Each of the whole-fund and deal-by-deal model, on its own, tends to favour one stakeholder’s interests over the other. Hybrid waterfall variations can however be used to strike a compromise and address specific goals. For example, a reduced carried interest rate can be applied on a deal-by-deal basis but then, once investors have recouped their capital and preferred return on a total return basis, the carried interest rate can be increased and the waterfall converted to a whole fund structure. Alternatively, the waterfall can be applied on a cumulative basis in respect of realised investments (but not from unrealised investments). The effect of this is that the sponsor can be rewarded more quickly for successful investments, but that losses from any subsequent unsuccessful realised investment which brings the fund below the hurdle will need to be made up by future distributions before the manager becomes entitled to further carried interest. Open-ended funds This note generally considers carried interest and waterfalls in the context of closed-ended fund structures. Per­form­ance-re­lated remuneration models have typically been less common in open-ended funds, which tend to prioritise long-term income returns over capital appreciation (and where capital proceeds are typically reinvested into the fund portfolio rather than distributed to participants). Where they have been employed, it was often in the form of a performance fee rather than a profit sharing arrangement. That being said, various open-ended funds have adopted per­form­ance-re­lated profit sharing structures (and this trend has increased in recent years). However these generally operate differently to closed-ended waterfall models, with the promote often being based on rolling calculation periods, with a notional IRR calculation applied to the starting and ending net asset values and related cashflows in respect of the applicable calculation period. Given the inherent differences between the closed and open-ended models, these promote arrangements are outside the scope of this note. ESG-linked carried interest Carried interest has traditionally been linked to the performance of funds against financial hurdles. However, the increased recent industry focus on ESG considerations, have seen certain stakeholders look to link carried interest and waterfalls to ESG, impact and sustainable investment criteria. This has proved an effective means of investors holding sponsor to account for their ESG performance, and for certain sponsors to differentiate themselves from competitors in a market that has seen a recent proliferation of sustainable investment strategies. There are varying methods of linking carried interest to ESG performance. For example, a portion of the traditional financial return-based carried interest may be held back subject to assessment of performance against impact-related KPIs. Alternatively, the fund’s hurdle rate may be lowered if certain impact-related KPIs are achieved. Other variations exist (e.g. requiring a portion of forfeited carried interest to be donated to charitable causes or to be used to purchase carbon offset credits). The complexity with all such models is in ensuring that impact KPIs are meaningful, measurable and appropriate to the investment strategy (or even individual investments within a strategy). ESG performance is inherently contextual, meaning that it can be difficult to accurately measure impact and outcomes, while as yet there are no clear or defined market standards. To provide greater alignment between sponsors and investors, funds will often rely on external experts, such as impact advisers and auditors, to provide independent guidance, oversight and verification of the process. For the reasons outlined above, ESG-linked carried interests have tended to be seen more commonly in strategies which pursue or promote a specific environmental and/or social objective or outcome, but have yet to become commonplace in the wider private funds industry. First loss mechanisms Last, but not least, there is also the option to use blended finance, where more risk-averse investors are hedged by investors with a higher risk appetite. This not only widens the pool of resources available to the sponsor, but allows investors to diversify their portfolio and enter into transactions outside of their usual risk profile. In a waterfall structure, this can take the form of a first loss mechanism under which an investor with a higher risk / return profile may agree to absorb a portion of losses (if they arise) against their contributions. In exchange, that investor may receive a greater preferred return and/or a preferred return contingent on a lower hurdle rate, meaning that if the overall portfolio performs well (with any losses recovered), that investor recoups higher and/or earlier profits than the more risk‑averse investors. Conclusion In structuring any fund product, it is crucial that the fund terms provide an appropriate alignment of interests between the sponsor and the investors. The distribution waterfall goes to the very heart of the fund (i.e. its performance and returns) and the various permutations (as set out above) provide an effective means of striking a balance between the respective interests of those key stakeholders, having regard to the strategy and purpose of the fund in question. If you would like specific advice on waterfall structures, including which model might be suitable to a particular transaction, please feel free to contact the CMS Funds Group.
17/05/2024
CMS International Construction Study 2024
CMS, in partnership with YouGov, asked in-house lawyers about the biggest challenges of managing disputes in this environment - and how those challenges can be met. We asked them about project risks, ESG factors and the use of AI in managing their transactions. Download the report to see what is keeping in house lawyers in construction businesses up at night, and how they see their risk landscape changing over the next few years.