TAILIEUCHUNG - German Tax Update 2013 and proposed changes in Luxembourg taxation

In relation to repurchase transactions, investors must notably be aware that (a) in the event of the failure of the counterparty with which cash of a sub-fund has been placed there is the risk that collateral received may yield less than the cash placed out, whether because of inaccurate pricing of the collateral, adverse market movements, a deterioration in the credit rating of issuers of the collateral, or the illiquidity of the market in which the collateral is traded; that (b) (i) locking cash in transactions of excessive size or duration, (ii) delays in recovering cash placed out, or (iii) difficulty in realising collateral. | cutting through complexity German Tax Update 2013 and proposed changes in Luxembourg taxation Andreas Patzner Gérard Laures Sébastien Labbé Claude Poncelet 05 December 2012 Agenda 1. Highlights on proposed Luxembourg Taxation 2. German Tax Update The AIFM-Directive The Annual Tax Act 2013 Circular of the Ministry of Finance dated 9. October 2009 2012 KPMG Luxembourg . a Luxembourg private limited company is a subsidiary of KPMG Europe LLP and a member of the KPMG network of independent member firms affiliated with KPMG International Cooperative KPMG International a Swiss entity. All rights reserved. 1 1. Luxembourg Tax Update 2012 KPMG Luxembourg . a Luxembourg private limited company is a subsidiary of KPMG Europe LLP and a member of the KPMG network of independent member firms affiliated with KPMG International Cooperative KPMG International a Swiss entity. All rights reserved.

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