Luxembourg Investment Vehicles

■Legal and regulatory requirements ■ Shareholding ■Reporting requirements ■ Approval and supervision ■ Taxation Supervised Investment Vehicles RAIF only with authorised AIFM Income tax If the RAIF does not invest in a portfolio of risk capital (such as a SICAR): tax exemption on income tax. If the RAIF invests in a portfolio of risk capital (such as a SICAR): • Tax exemption for income and capital gain derived from transferable securities connected with investments in risk bearing capital. • Tax exemption for one year for income on cash held for the purpose of a future investment. •The remaining income is subject to the ordinary income tax of 24.94 % (Municipal Business Tax + Corporate Income Tax - Luxembourg city 2019). Withholding tax on dividends and capital gains Not subject to withholding tax. Subscription tax If the RAIF does not invest in a portfolio of risk capital (such as a SICAR): • 0.01% of NAV annually. • Tax exemption possible for certain money market, microfinance funds and pension funds or RAIFs investing in other funds already subject to subscription tax. If the RAIF invests in a portfolio of risk capital (such as a SICAR): no subscription tax. Net wealth tax Only subject to minimum net wealth tax if the RAIF does invest in a portfolio of risk capital (such as a SICAR). Capital duty No proportional capital duty. Value Added tax (VAT) SCS with authorised AIFM Fiscally transparent for corporate income and net wealth tax purposes. Partnerships which qualify as AIFs according to the AIFMD are not subject to Luxembourg municipal business tax as they are not considered as carrying out a commercial activity. SCSP with authorised AIFM Fiscally transparent for corporate income and net wealth tax purposes. Partnerships which qualify as AIFs according to the AIFMD are not subject to Luxembourg municipal business tax as they are not considered as carrying out a commercial activity. Not subject to withholding tax. Not subject to withholding tax. No subscription tax. Not subject to net wealth tax as considered to be fiscally transparent. No proportional capital duty. No subscription tax. Not subject to net wealth tax as considered to be fiscally transparent. No proportional capital duty. Luxembourg Investment Vehicles KPMG VAT exemption on management services. VAT exemption on management services. VAT exemption on management services. 37 37

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