Global Fund Prospectus - Jupiter Asset Management

THE JUPITER GLOBAL FUNDTaxation■■TaxationThe following information is based on the law and practice currently inforce in Luxembourg. The information is not exhaustive and, if potentialinvestors are in any doubt as to their taxation position, they shouldconsult their professional adviser. Investors should note that tax lawand interpretation can change and that, in particular, the levels andbases of, and reliefs from, taxation may change and that changes mayalter the benefits of investment in the Company.The CompanyThe Company is not subject to any Luxembourg tax on profits orincome. However, as at the date of publication of this Prospectus, theCompany is liable in Luxembourg to a taxe d’abonnement of 0.05%per annum of its NAV, such tax being payable quarterly on the basisof the value of the net assets of the relevant Fund at the end of therelevant calendar quarter. The taxe d’abonnement is levied at a rate of0.01% per annum on Funds or Classes reserved to InstitutionalInvestors. No such tax will be payable in respect of the portion of theassets of the Fund invested in other Luxembourg collective investmentundertakings. No Stamp Duty or other tax is payable in Luxembourgon the issue of Shares.No Luxembourg tax is payable on the realised or unrealised capitalappreciation of the assets of the Company. Income received from theCompany on its investments may be subject to non-recoverablewithholding and other taxes in the countries of origin. Neither theInvestment Manager nor the Custodian will obtain receipts for suchtaxes either for individual or for all Shareholders. However, theCompany may benefit from certain double-tax treaties and be able inthese cases to recover the withholding taxes in the country of origin.The Directors intend that the Company should so conduct its affairsthat it will be resident in Luxembourg for tax purposes.Taxation of Shareholders in LuxembourgUnder current Luxembourg legislation, Shareholders may be subjectto capital gains, income, inheritance or other taxes dependent ontheir individual circumstances. Shareholders should consult theirown professional adviser if they are in any doubt as to their owntaxation position.i) Luxembourg residents:ii)Shareholders resident in Luxembourg will be liable to tax oncapital gains on the disposal of any holding in the Company ifthey have held more than 10% of the share capital of theCompany at any time during the five years preceding thedisposal (important participation). Shareholders holding lessthan 10% of the share capital of the Company at any time duringthe five years preceding the disposal will not be liable to tax oncapital gains unless they dispose of their holding within sixmonths of the date of acquisition. Dividend income will be subjectto income tax in the hands of a Luxembourg resident Shareholder.Shareholders not resident in Luxembourg:The information in this section is subject to and qualified by theEU tax considerations set forth below.A disposal of a holding in the Company will constitute a disposalfor the purposes of Luxembourg tax on capital gains. Luxembourgtax on capital gains is generally overruled by applicabledouble-tax treaties however, Shareholders who are in any doubtover their position are advised to consult their own professionaladviser. The tax treaty between Luxembourg and the UKexempts UK resident Shareholders from Luxembourg tax oncapital gains.Subject to the EU provisions detailed below, dividends received byLuxembourg non-residents are not subject to Luxembourg tax.There is no withholding tax on the distributions paid by the Companywhether or not the Shareholder is resident in Luxembourg.EU Tax Considerations for Individuals Resident in the EU or inCertain Third Countries or Dependent or Associated TerritoriesThe EU Council Directive 2003/48/EC on taxation of savings incomein the form of interest payments (the ‘Directive’) provides that from1 July 2005, paying agents established in a member state of the EU orcertain dependent or associated territories of member states whomake savings income payments to individuals resident in anothermember state or to residual entities within the sense of the Directive(and depending on the jurisdiction of establishment of the payingagent, possibly also to individuals and residual entities within thesense of the Directive resident in certain dependent or associatedterritories of member states) will be obliged, depending on thejurisdiction of the payment agent either to report details of the paymentand payee to fiscal authorities or to withhold tax from it. A furtheroption allowing an EU resident to submit an exemption certificate isalso available. The Luxembourg law of 21 June 2005 (the ‘2005 Law’)has implemented the Directive into national law.Although exchange of information is the ultimate objective of theDirective, Luxembourg, Austria and certain dependent or associatedterritories of EU Member states (such as Jersey and Guernsey) haveopted to apply withholding tax during a transitional period. Underthese arrangements, withholding tax will apply when a Luxembourgpaying agent makes distributions from and redemptions of shares incertain funds and where the beneficiary of these proceeds falls withinthe scope of the Directive. However, an individual may specificallyrequire to be brought within the Directive exchange of informationregime which would result in no withholding tax being applied butinstead information regarding the distribution being provided to thefiscal authority in his country of residence.Dividends distributed by a Fund of the Company will be subject tothese obligations if more than 15% of such Fund’s assets are investedin debt claims as defined in the 2005 Law and proceeds realised byShareholders on the redemption or sale of Shares in a Fund will besubject to the Directive or 2005 Law if more than 25% of such Fund’sassets are invested in debt claims. The applicable withholding tax is ata rate of 35% since 1 July 2011.The Company and the Administrator reserve the right to reject anyapplication for Shares if the information provided by any prospectiveinvestor does not meet the standards required by the 2005 Law as aresult of the Directive.GeneralThe above statements regarding taxation are based on advicereceived by the Company regarding the law and practice in force atthe date of this document. Prospective investors should be aware thatlevels and bases of taxation are subject to change and that the valueof any relief from taxation depends upon the individual circumstancesof the tax payer.28