1E9Ct5D

TAX REGIMEUnregulatedSpecial PurposeVehicles inCorporate FormUnregulatedSecuritisationVehiclesTax Regime SPVs are subject to: Securitisationvehicles in the formof companies aresubject to: CorporateIncome Tax MunicipalBusiness Tax(combined rate of29.22%)The SPV is subjectto net worth taxamounting to 0.5%of the net assets.However, equityparticipations heldby the SPV whichwould qualify underthe participationexemption areexemptCorporate IncomeTax MunicipalBusiness Tax(combined rate of29.22%)Deduction of alloperational costs.SPVs are exemptfrom: Subscriptiontax.Agreements relatingto a securitisationtransaction need notbe registered(except thosetransferring rights inreal estate locatedin Luxembourg or invessels or aircraftsregistered inLuxembourg).Managementservices are VATexemptRisk CapitalStructures (SICAR)SICARs organised ascapital companies aresubject to:Corporate IncomeTax Municipal BusinessTax(combined rate of29.22%)SICAR is exempt inLuxembourg fromcorporate income tax onincome fromtransferable securitiesas well as on incomefrom their sale orliquidation, includingdividends, interest andcapital gains. Incomearising from fundsawaiting investment inrisk capital is alsoexempt from tax. If ascs or scsp, the SICARis not liable forcorporate or net worthtax or municipalbusiness tax, as it isconsidered a lookthroughentity, and allincome is deemedtaxable directly at thepartner level (so long asany general partner thatis a Luxembourgcompany holds lessthan 5 % of the scsp).SICARs are exemptfrom net worth tax andsubscription tax. TheSICAR must pay to theCSSF a minimumannual fee of € 3,000SpecialisedInvestment Funds(SIF)In principle, nowithholding tax on capitalgains for non-residentinvestorsSIFs are subject to anannual subscription tax of0.01 % levied on netasset value on the lastday of each quarter of theyear. The SIF Law,however, provides forseveral exemptions.If a limited partnership(s.c.s.) or special limitedpartnership (s.c.s.p.), theSIF is not liable forcorporate or net worth tax;however, this applies inrespect of MBT only to theextent that any generalpartner that is aLuxembourg companyholds less that 5% of thepartnership interests ofthe s.c.s. or s.c.s.p.The SIF must pay to theCSSF a minimum annualfee of € 3,000Private WealthManagementCompany(SPF)Not subject to CIT,MBT, or NWT. Inprinciple, nowithholding tax ondividenddistributions or oncapital gains tonon-residentinvestors.SPFs are subjectto an annualsubscription tax of0.25% levied onpaid-in capital plusshare premiumplus an amount bywhich its debtexceeds eighttimes the amountof capital plusshare premium14