Funds taxation

Funds taxation

Participants in the global asset management industry are facing unprecedented complication of managing their tax affairs both locally and across multiple jurisdictions.

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KPMG in Luxembourg

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Fund Taxation

Background

KPMG Luxembourg’s Financial Services Tax Team recognizes the increasing need of a market for specialized tax advice. We are highly experienced tax professionals, ready to assist you to manage your tax risks and opportunities.

Our services

Supported by KPMG tax professionals around the world, we bring our local and cross-border expertise in all matters of tax at the level of the investor, the fund structure (including ManCo) and the investment, including:

  • Tax advisory services
    • Income and municipal business tax
    • Withholding tax
    • Net wealth tax
    • Subscription tax
    • Transfer pricing aspects
    • Tax reporting obligations
    • Exchange of information (including FATCA)
    • Substance requirements
    • Establishment of tax matrixes (e.g. withholding taxes, capital gains taxes, stamp duties)
 
  • Set-up & structuring
    • Advice in the set-up of fund and investment structures (including the choice of vehicle and structuring of alternative investments, e.g. real estate and private equity)
    • Substance requirements and transfer pricing for management companies
    • Advice in the choice of investments and income/ cash repatriation
    • M&A activities and Master-Feeder structures
    • Redomiciliation of foreign investment funds to Luxembourg
    • Optimization of (cross-border) distribution schemes
 
  • Tax reviews, including
    • Review of direct tax risks and opportunities (selected transactions / whole business);
    • Review of withholding tax exposure (for further information on the specific case of withholding tax reclaims based on favorable ECJ decisions)
 
  • Reclaim of withholding taxes at investor and fund level
 
  • Assistance with tax compliance obligations
 
  • Assistance with tax audits
 
  • Update on recent tax developments
 
  • Trainings in selected tax matters
 
  • Tax hotline/ news alerts

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