BEPS’ rules on Permanent Establishment mean that offshore directors will probably have to show that they make the decisions on the funds on whose boards they sit. Otherwise the fund may well fall foul of BEPS’ rules on Permanent Establishment. BEPS could well have a massive impact on this business.

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The fund director universe is diversifying; choice is broadening at present. Judging by some of the newer subscribers to The NED it seems that more people are trying their hand as directors with different – and perhaps complementary - skill sets from many of those that have done this job that are based in one or other of the international fund jurisdictions.

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