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ARTICLE · 24 JULY 2017

Oiling The Right Places In The Fund Machine

With the current investment rate environment being what it is—low—fund managers and management companies are looking for more stability and better returns. However, for many, this is proving difficult.

LuxembourgTax

With the current investment rate environment being what it is—low—fund managers and management companies are looking for more stability and better returns. However, for many, this is proving difficult. The complexity of fund structures means that it could be easy to overlook certain processes that could be improved—where should you even begin? In my industry experience I have seen a recurring area that fund managers should be thinking about: withholding tax.

What I've seen is that sub-custodians, which are often part of bigger groups, tend to minimise their own risk of liability towards tax authorities by, when in doubt, levying more rather than less tax. This strategy makes perfect sense because nobody wants to be the weakest chain in the group by incurring tax penalties by local governments. Administrators and custodians, for their part, typically have time to cover some tax reclaims and relief at source but often not the entire range of investment markets. The tax

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