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By Nicolas GILLET, Partner, Transfer Pricing Leader ; Patricia GUDINO JONAS, Partner, Tax and Chiara PALMIERI, Manager, Transfer Pricing at EY Luxembourg
“Substance” is a key topic in the setup of investment structures. However, the concept of substance is generic and could encompass various and potentially different items. It could also be interpreted differently between tax authorities and regulators. From a tax perspective, it usually describes beneficial ownership requirements and tax treaty access. From a regulatory perspective, decision-making functions are key areas of attention by regulators for Alternative Investment Funds (AIFs) managed by an Investment Fund Manager (IFM).
From a...
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