thesis_kogut_i6051085.pdf
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… http://en.wikipedia.org/wiki/Member_State http://en.wikipedia.org/wiki/Financial_services 8 A private equity fund can be defined as a form of equity investment into private companies that are not quoted on a stock exchange. Private equity is distinguished by its active investment model, in which it seeks to deliver operational improvements in its companies, over several years 5 . Private equity funds differ from UCITS with regard to the types of investors, the … a SIF (0,01%) but may be reduced or even not levied at all under certain conditions. 29 Although Luxembourg standard withholding tax rate is 15%, there are usually no withholding taxes on dividends paid by the Luxembourgish fund to its domestic and foreign investors, except if the EU Savings Directive applies (see section 2.2.3.5 of the present thesis below). This is due to the application of the EU Parent-Subsidiary Directive and due to the fact that Luxembourg has extended the benefits of the … commercial by reason of its legal form), the whole activity of the Luxembourg partnership is deemed to be commercial. This infects the partnerships, making the SCS and SCSp subject to Luxembourg municipal business tax on its income and gains, and the foreign partners to corporate income tax and net wealth tax in Luxembourg due to the presence of a Luxembourg permanent establishment. To avoid this undesired tax barrier Luxembourg has recently taken some measures aimed at relaxation of the conditions …