Luxembourg Regulated Investment Vehicles - Alfi

Taxation20Part I Fund (UCITS)Part II Fund (UCI)Income tax Tax exempt Tax exemptWithholding tax ondividends and capitalgainsNot subject to withholding tax except ifEU savings directive applies.Not subject to withholding tax except ifEU savings directive applies.Subscription tax• 0.05% of NAV for equity fund.• 0.01%of NAV for money market cashfunds and institutional fund.• Exemption for special institutionalmoney market cash funds, pensionfunds and funds investing in other fundsalready subject to the subscription tax.• 0.05% of NAV for equity fund.• 0.01%of NAV for money market cashfunds and institutional fund.• Exemption for special institutionalmoney market cash funds, pensionfunds and funds investing in other fundsalready subject to the subscription tax.Net wealth tax Tax exempt Tax exemptCapital duty No proportional capital duty No proportional capital dutyValue Added tax (VAT) Tax exemption on management services. Tax exemption on management services.Double Taxation Treaties(DTT)FCPNo access to DTT signed by Luxembourg;exception Ireland.FCPNo access to DTT signed by Luxembourg;exception Ireland.SICAV/SICAFLimited to some DTTs.Applicability of DTTs is determined bya decision taken by the Luxembourgfiscal authorities, but without practicalexperience on the exact classification thatmay be adopted by the other countries.SICAV/SICAFLimited to some DTTs.Applicability of DTTs is determined bya decision taken by the Luxembourgfiscal authorities, but without practicalexperience on the exact classification thatmay be adopted by the other countries.