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By Joakim-Antoine CHARVET, Partner, Head of Tax and Delphine MARTEL, Managing Associate Tax Linklaters Luxembourg
Investors stepping into the realm of investment fund subscriptions are finding themselves at the crossroads of an increasingly complex tax and compliance environment. Once part of a mere procedural step formalising the investor’s capital contribution due upon admission to the fund, subscription documents have evolved into an essential tool for assessing the impact of certain tax implications in line with evolving tax regulations.
This transformation has been particularly evident with the anti-hybrid rules introduced following Council Directive (EU) 2017/952 as regards hybrid mismatches with third countries (“ATAD 2”) and the...
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