Luxembourg Regulated Investment Vehicles - Alfi

21SIF SICAR Securitization vehicle – regulatedTax exemptNot subject to withholding tax exceptif EU savings directive applies.sTax exemption for income derivedfrom transferable securities.Tax exemption for one year forincome on cash held for the purposeof a future investment.The remaining income is subject to theordinary income tax of 28,59 %(Municipal Business Tax + CorporateIncome Tax - Luxembourg city 2010).Not subject to withholding tax exceptif EU savings directive applies.Securitization companyFully taxable at a rate of 28,59%(Municipal Business Tax + CorporateIncome Tax - Luxembourg city 2010).A reduction of the taxable income toclose to e 0 is possible (engagementsmade to investors and other creditorsare fully tax deductible).Securitization fundTax exemptNot subject to withholding tax exceptif EU savings directive applies.• Annually 0.01% of NAV.• Tax exemption possible for certainmoney market and pension fundsor SIFs investing in other fundsalready subject to subscription tax.No subscription tax.Securitization companyNo subscription tax.Securitization fundTax exemption.Tax exempt Tax exempt Tax exemptNo proportional capital duty No proportional capital duty No proportional capital dutyTax exemption on managementservices.FCPNo access to DTT signed byLuxembourg; 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 classificationthat may be adopted by the othercountries.Tax exemption on managementservices.SICAR in the form of a corporateentity (all types except the SCS)should benefit from the Luxembourgdouble tax treaty network.Tax exemption on managementservices.Securitization companyYes (all types except the SCS).Securitization fundNo access to DTT.