tailieunhanh - Luxembourg Investment Funds Withholding Tax Study 2011

The data is limited in some respects. We do not have information on total net assets, nor do we know the exact location of the portfolio manager, so we use the fund's legal domicile as a proxy for the manager's location. 9 We also have limited data on front-end and redemption loads, as well as total fund expense ratios. Moreover, we do not have data on many of the individual funds' expenses and fees, particularly during the early part of the sample (we searched for these data, and none of the major services{., Morningstar{appear to have historical data covering our entire sample period). . | À V I I w cutting through complexity LUXEMBOURG INVESTMENT FUNDS Withholding Tax Study 2011 Update July 2011 Introduction On behalf of KPMG s Funds Line of Business we are pleased to introduce the 2011 Luxembourg Investment Funds -Withholding Tax Study. We are delighted to present to you the Luxembourg Investment Funds - Withholding Tax Study 2011 update which is the fourth edition of this study. The report addresses the comparison of the competitive advantages of investing in different jurisdictions through a Luxembourg SICAV or Luxembourg FCP The research includes a survey of 72 countries as well as an in-depth analysis of the stage of interest taxes dividend taxes capital gains tax and withholding rates applying to Luxembourg SICAVs and FCPs. In addition we discuss the possibility for Luxembourg SICAVs and FCPs to reclaim withholding tax based on EU Law the EU Commission s actions as well as administrative and juridical decisions. We also outline the provisions within the newly introduced US withholding tax system . Foreign Account Tax Compliance Act FATCA and their implications for the investment fund industry. We hope you find the material of interest and should you seek further information on the report we would be delighted to assist you in your queries. Please feel free to contact us if you have any questions or if you would like additional copies. Soft copies are also available from our website Finally we would also like to thank all those who offered their valuable time to help complete the survey. Vincent Heymans Partner Gérard Laures Partner How to further reduce withholding tax based on EU Law In the last 6 years EU law has increasingly impacted the European tax environment and its consequences for the Luxembourg investment fund industry should no longer be underestimated. Recent ECJ case law Aberdeen Fininvest Alpha C-303 07 EU Commission s actions as well as local administrative and judicial decisions provide a solid basis for

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