Tax Treatment of PLNs
For immediate release 2 December 2003
PANTHEON INTERNATIONAL PARTICIPATIONS PLC
TAX TREATMENT OF PARTICIPATING LOAN NOTES
The Board of Pantheon International Participations PLC ('PIP' or the 'Company')
notes the proposals published by Jupiter Global Green Investment Trust Plc on
21 November for the conversion of its Participating Loan Notes ('PLNs').
In the light of these proposals, the Board wishes to confirm the advice it has
received from its professional tax advisers on the tax treatment of PIP in
relation to its PLNs. The Board has been advised that no provision for taxation
is required in the accounts of the Company to date in relation to its PLNs.
The PLN's fall to be taxed under the loan relationships regime. Accordingly any
fall in the Adjusted Redemption Value of the PLNs ('ARV') either on redemption
or as reflected in the Company's accounts from year to year is likely to
represent a taxable profit of the Company. Conversely, any increase in the ARV
which is either realized on redemption (where not classified as a distribution
for tax purposes) or recognised in the Company's accounts as at the end of any
year is likely to result in the Company being treated for tax purposes as
having made a loss equal to the amount of the increase.
The board believes PIP is in a different position from Jupiter Global Green
Investment Trust Plc because, over the period since PLNs were first issued by
PIP, the ARV of the PLNs has not fallen significantly below the average value
at which PLNs have been issued. Although the ARV of the PLNs fell by 19.2% in
the year to 30 June 2002 and PLNs were redeemed in February 2002 at a
redemption price lower than the ARV reflected in the Company's accounts as at
the end of the immediately preceding accounting period, the tax losses brought
forward from the rise in the ARV for PLNs for prior accounting periods,
together with surplus expenses which PIP accumulated over these periods, should
more than offset any resulting taxable profit. Since 30 June 2002, the reported
ARV has risen by approximately 4.3%
On the basis of the PLNs presently in issue, the value of the Company's net
assets would need to fall significantly from the latest reported level before
material tax liabilities are triggered.
The Board continues to review the capital structure of the Company to ensure
that there are continuing benefits to the Company from the use of PLNs and will
report as necessary in due course.
For more information:
Pantheon International Participations PLC 020 7484 6200
Rhoddy Swire
Pantheon Ventures 020 7484 6200
Andrew Lebus
Alastair Bruce
www.pipplc.com contactus@pipplc.com
NOTES TO EDITORS
PIP
* Pantheon International Participations (`PIP') is a London quoted investment
trust, managed by Pantheon Ventures Ltd., which uses an international
fund-of-funds approach to private equity investment.
* PIP has investments in some 300 private equity funds whose portfolios
contain investments in over 3,000 companies.
* The Company is the leading independent private equity fund-of-funds
investor quoted on the London Stock Exchange. PIP enables individuals as
well as institutions to gain access to a substantial portfolio of unquoted
companies in the USA, UK, Continental Europe and Asia, within funds managed
by experienced private equity managers.
* Within its stated primary investment objective, the Company invests in
private equity funds both by subscribing to new funds and by acquiring
secondary interests. As an adjunct to this activity, the Company may
occasionally acquire direct holdings in unquoted companies usually where a
vendor is seeking to sell a combined portfolio of funds and direct
holdings. PIP's investment policy also extends to investing directly in
companies where there is a private equity manager well known to the Company
investing on the same terms.
Pantheon Ventures Limited
* Pantheon has been active in the private equity sector since 1982.
* Pantheon is the leading private equity fund-of-funds manager in Europe and
currently manages over $6.9 billion.
* Pantheon manages investments in 500 private equity funds in over 30
countries.
* Pantheon has 65 staff, based at offices in London, San Francisco, Hong Kong
and Brussels.
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