20 December 2017 Luxembourg releases new guidelines on certificates of residence for UCIs The Luxembourg Tax Administration (LTA) has released a new administrative Circular (the Circular), providing details on the issuance of certificates of residence for Luxembourg undertakings for collective investment (UCIs). The new Circular now also covers Reserved Alternative Investment Funds (RAIFs) set-up in accordance with the provisions of the law of July 23, 2016. It also updates the list of double taxation treaties (DTTs) accessible to UCIs. In general, the issuance of these residency certificates is key when determining whether a Luxembourg UCI may have access to a DTT's provisions and benefits. Regardless of the availability of such residency certificates, not all of the DTTs concluded by Luxembourg are applicable to UCIs. Accordingly, a case-by-case analysis of a DTT's application remains necessary. Document ID: 2017-2152 |
