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ARTICLE · 23 APRIL 2015

Certificates Of Residence For Funds

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A certificate issued by the LTA only reflects the position of the LTA with regards to the residence and qualification of a UCI under a specific double tax treaty.

LuxembourgTax

Circular L.G. – A. n°61 issued on February 12th 2015 (hereafter the "Circular") by the Luxembourg tax authorities (hereafter the "LTA") aims at clarifying their position with regards to the issuance of certificates of residence for undertakings for collective investments (hereafter "UCIs") as well as the specific procedure to be followed depending on the type of UCIs and the relevant country requesting the certificate of residence.

A certificate issued by the LTA only reflects the position of the LTA with regards to the residence and qualification of a UCI under a specific double tax treaty. This unilateral position may not be shared by the other treaty country.

In the Circular, the LTA sets out three different types of certificates of residence.

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