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Luxembourg Investment and Fund RaisingVehicles

11 October 2012


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Agenda

Why Luxembourg

Luxembourg Investment Vehicles

Features of the Investment Vehicles

Fund Raising Vehicles

SIF and SICAR - comparison


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Why Luxembourg

A historic role in Europe

A safe and financially healthy country

A top level financial cluster

A competitive business center

Luxembourg has a proven expertise in :

Wealth management

Attractive approach in taxation

Geographical location in the heart of the biggest art market in the world

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Why Luxembourg

2005

Venture

Capital

Microfinance

Securitisation

vehicles

intellectual

property

SIF

Covered

bonds

SPF

2012

Pension funds

Philantropy

Pension pooling

vehicles

Fund

administration

Coveredbonds

Covered

bonds

Ongoing diversification


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Why Luxembourg Choosing the right investment vehicle

Type

ofinvestor

Private

Corporate

Size of the Portfolio

SICAR SICAV/FCP

LargeSmall

SPF SIF

SOPARFI

Choosing the right investment vehicle


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Luxembourg Investment Vehicles

Fully regulated

vehicles

Non-regulated

vehicles

Partially regulated

vehicles

FCP

SICAF/SICAV

SOPARFI

SPF

SIF

SICAR

SV


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Features of the Investment Vehicles

Regulated

FCP Based on contract, fiscally transparent

SICAF Investment company with fixed capital

SICAV Investment company with variable capital

Partially regulated SIF Investment company for qualified or institutional investors

SICAR Investment company for venture capital

SV Securitization company

Unregulated

SOPARFI Holding company for participations

SPF Holding company for share and participations


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Fund raising vehicles

SICAR (Societe dInvestissementen Capital a Risque)

vehicle designed for private equity and venture capital

SIF (Specialized Investment Funds)

flexible and lightly regulated UCI


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SIF and SICAR comparison

Key topics SIF SICAR

Why? Pooling of qualified investors

requiring a lightly regulated fund

Pooling of qualified investors

requiring a lightly regulated fund

(and intermediate holding

company)

Investment objective

Legal form

Any asset/risk spreading Corporation (SICAV/SICAF) or

mutual fund (FCP)/

compartments

Investment(s) at risk/ nodiversification required

Corporationor partnership

Minimum share capital or net

assets

1.25m 1m

Regulatory supervision

Lightly regulated

Lightly regulatedInvestors profile Institutional or Professional or

Well-informed Investors

Institutional or Professional or

Well-informed Investors

Net worth tax No No


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SIF and SICAR comparison (continued)


Subscription tax 0.01% p.a. on net assets No

Corporate income tax

(world-wide base, unless DTT

applies)

No Yes if corporate SICAR

28.80 % (if taxable corporate

entity) Tax exempt income

from transferable securities(equity and debt)

No if tax transparent SICAR

WHT on dividends No No

WHT on interest and royalties No(a) No(a)

Note: (a) With exceptions for interest (EUSD and withholding tax for Luxembourg resident individual recipient)


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SIF and SICAR comparison (continued)


WHT on liquidation proceeds No No

Benefit from the EC Parent-

Subsidiary Directive

No Yes if corporate SICAR


Benefit from the EC Interestand Royalty Directive

No

Yes

if corporate SICAR No if tax transparent SICAR

Double tax treaty protection Possible if SICAV/SICAF

(under certain DTTs) Yes if corporate SICAR


VAT Exempt management activities Exempt management activities


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Contact us

Your Experta Luxembourg Advisors:

Giuliano Bidoli

Head of Tax

Member of the Executive Board

Tel: +352 269 255 5171

Mobile: +352 621 349 475

Fax: +352 269 255 3641

[email protected]

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