Abstract
Existing forms of collective investment of capital address different groups of investors and in many cases are tailored to their specific needs. These fund structures are essentially characterized by two main features. Firstly, several different structures are possible in legal terms. These vary considerably from country to country. Secondly, fund structures often display a distinctly international orientation; in many cases funds address investors around the globe and invest the capital made available in international investment assets. As a rule, the investments are not limited to the country where the funds are based. From this it follows that the fund structures result in highly complex taxation issues, raising numerous problems in detail and matters of doubt. This holds especially with respect to cross-border taxation issues. Due to the vast number of fund vehicles operating in the various countries, it is scarcely possible for an investor to determine at a glance which investment is tax optimal from his or her particular perspective.
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Notes
- 1.
For methodological reasons the groups of institutional investors and cross-border fund-structures of considerable significance in practice cannot be taken into account in the framework of the quantitative analysis.
- 2.
Cf. German Financial Supervisory Authority (2012).
- 3.
In principle, in the majority of countries observed no significant changes in investment taxation law relevant to the present study have since taken place. Exceptions apply in the case of Italy and the UK which is why the legal status of July 2012 is referred to here. Moreover, as far as Germany is concerned, the legal status as of March 2013 is applied due to recent changes in the taxation of dividend income accrued to publicly traded investment funds.
Reference
German Financial Supervisory Authority (2012) List of admissible investment trust companies and investment corporations with variable capital. http://www.bafin.de/SharedDocs/Downloads/DE/Liste/Unternehmensdatenbank/dl_li_kag_invag_zugel.xls?__blob=publicationFile&v=1. Accessed December 15, 2012
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Oestreicher, A., Hammer, M. (2014). Introduction. In: Oestreicher, A., Hammer, M. (eds) Taxation of Income from Domestic and Cross-border Collective Investment. Springer, Cham. https://doi.org/10.1007/978-3-319-00449-5_1
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DOI: https://doi.org/10.1007/978-3-319-00449-5_1
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