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23 March 2016

Attractive tax regime for the future RAIFs

Luxembourg is going to create a new type of Luxembourg alternative investment fund called Reserved Alternative Investment Fund (”RAIF”).

Unlike other Luxembourg funds such Specialised Investment Funds (SIFs) or investment companies in risk capital (SICARs), RAIFs will not be subject to prior approval and supervision of the Luxembourg Supervisory Authority (“CSSF”). But RAIFs will benefit from the same flexibility and tax regime as both SIFs or SICARs.

 

The tax regime of RAIFs depends on the investment strategy of the fund.

 

  • They are subject to the same tax regime as SIFs:

- exemption of corporate income tax, municipal business tax, withholding tax on distributions and net wealth tax

- payment of an annual subscription tax of 0.01% of their net asset value of the last day of every calendar quarter, with some exemptions applicable under certain conditions

 

  • But if they only invest in risk capital, RAIFs are subject to the same tax regime as SICARs:

- payment of corporate income tax and municipal business tax

- exemption of income deriving from transferable securities

- withholding tax exemption on dividends

- exemption of Net Wealth Tax

 

In general, the VAT exemption on AIF management services applies.

 

Creatrust acts as a one-stop-shop to provide Investment Managers and Promoters with the optimal solution. Creatrust's expertise includes:

 

 

 

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