Background
The UCITS IV Directive introduces a full passport for the UCITS Management Company, a framework for cross-border UCITS mergers and Master-feeder UCITS structures. Tax considerations will play an important role in these three areas. They are still uncertain as the UCITS IV Directive is focusing on legal and regulatory themes, excluding the tax one. UCITS IV, however, covers investments funds marketed essentially to retail investors. The essence of the UCITS Directives has always been to create a secure brand for these investors. The present article aims at highlighting the main tax issues based on the existing tax legislations and an outlook on what needs to be done in order to ensure that tax matters are not going to impede the successful implementation of the...
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