TAILIEUCHUNG - Luxembourg Investment Funds Withholding Tax Study 2012

There are several way so sustain the pure components equilibrium we have solved. Most importantly, the two goods in question can have di erent life-cycles leading to existence of consumers who already own one of the goods and are shopping only for the other. If number of such consumers is substantial the small gains that bundling brings can be o set with losses from these consumers who will be less likely to buy a bundle. Clearly we have not dealt with such consumers in our paper but we strongly believe that such an extension will not change the main ndings of our model while eliminating bundling as a protable. | Withholding Tax Study 2012 Update July 2012 cutting through complexity LUXEMBOURG INVESTMENT FUNDS Introduction On behalf of KPMG s Funds Line of Business we are delighted to present to you the Luxembourg Investment Funds -Withholding Tax Study 2012 update which is the fifth edition of this study. The research includes a survey of 72 countries as well as an in-depth analysis of the stage of interest taxes dividend taxes capital gains tax and withholding rates applying to Luxembourg SICAVs and FCPs updated as of June 2012. In addition we discuss the possibility for Luxembourg SICAVs and FCPs to reclaim withholding tax based on EU Law the EU Commission s actions as well as administrative and juridical decisions. We also outline the provisions of the US FATCA Foreign Account Tax Compliance Act system and their implications for the investment fund industry. We hope you find the material of interest and should you seek further information on the report we would be pleased to assist you in your queries. Please feel free to contact us if you have any questions or if you would like additional copies. Soft copies are also available from our website Finally we would also like to thank all those who offered their valuable time to help complete the survey. Vincent Heymans Partner Gérard Laures Partner How to further reduce withholding tax based on EU Law In the last 7 years EU law has increasingly impacted the European tax environment and its consequences for the Luxembourg investment fund industry should no longer be underestimated. ECJ case law Aberdeen Fininvest Alpha C-303 07 and Santander case C-3381 EU Commission s actions as well as local administrative and judicial decisions provide a solid basis for Luxembourg investment funds and FCPs to reclaim unduly levied withholding taxes in the EU Member States where they have made investments. As a consequence the Withholding Tax Study 2012 includes since several years the amount of withholding tax that .

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