Investment Fund Analysis & Strategy

Investment vehicle - corporate/holding LP Belgian resident No-Belgian resident Foreign Co BelCo 1 BelCo 2 PwC GP Holding Portfolio No custody enshrined in law - but achievable under conditions ✓ Tax neutrality is achievable but subject to conditions (exemption of the vehicle and availability of general WHT exemptions) × Tax exemption is limited by eligible investment (eg. participation exemption regime) X / ✓ Foreign investor: depends on local tax law, but benefit of EU Directives ✓ No yearly tax on undertakings ✓ Not subject to asset test 20 20

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