Investment Fund Analysis & Strategy

Anti-treaty shopping measures and hybrid mismatches Profit repatriation without WHT Profit repatriation without WHT PwC Investors Fund Context • Funds rely on DTT to secure a tax neutral repatriation of profits to investors Substance & beneficial ownership conditions to access the treaties are getting stricter A limitation on benefits (LOB) clause & principal purpose test (PPT) will likely be added to most treaties Impact for funds Access to DTT for holdings • TopCo Beneficial ownership Needs for true economic purpose, key substance and no legal obligation for redistribution Target Group 26 26

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