INVESTINVENTURE.COM
		The following information is relative to the tax treatment of Venture Capital entities in various countries as is in 2010. The information is the result of interpretation of the wording of various documents (officials or not) found on Internet. Therefore, the information provided below should NOT be considered 100% accurate. You should be officially informed by the tax authorities of the countries listed below. Investinventure.com shall not be liable for any kind of loss that may occur from decisions made according to the information provided below, or based on any other content of this site. If you cant properly read some words on this page please go to View/Encoding and try to find and select the Unicode (UTF-8) on Internet Explorer, or View/Character Encoding/More Encodings/Unicode/Unicode (UTF-8) on Firefox. Country Venture capital Vehicles Investment Target Tax Base Person to be taxed Tax Rate Other Useful Link United Kingdom English Limited Partnership -ELP- Venture Capital investments in the UK(typically under £1million). Investment income and capital gains Partners - Investors are supposed to claim any treaty credits etc. by making their own tax filings.   Germany Venture Capital holding companies or partnerships. GmbH & Co. KG (Kommanditgesellschaft), is the legal form of limited partnership, whose sole general partner is a GmbH. GmbH, is the German legal form of company with limited liability non-listed EU / EEA companies . he above companies should be founded within the last ten years, and its equity - at the time when the investment is made – does not exceed EUR 20m Dividends and capital gains The company Partners in case of partnerships German corporate income tax rate plus solidarity surcharge is 15.825% (year2010)   Tax exemption (95% of dividends and capital gains which a corporate entity derives from a corporate target company). Other special provisions apply The registered office and place of management of the VC Fund Vehicle should be in Germany. German Financial Supervisory Authority (Bundesanstalt für Finanzdienstleistung saufsicht France An FCPR can be used for French and foreign investments. Two types of FCPR: 1) Fonds commun de placement dans l’innovation (FCPI) and 2) Fonds d’investissement de proximité (FIP) SCR ‘société de capital risque’ for VC investments in France. (SUIR), ‘société unipersonnelle d’investissement à risques/régional’ and the (JEI) ‘jeune entreprise innovante’ usually have a legal personality and are considered as opaque for tax purposes n.a. If you cant properly read some words in this case please go to View/Encoding and try to find and select the Unicode (UTF-8) on Internet Explorer, or View/Character Encoding/More Encodings/Unicode/Unicode (UTF-8) on Firefox. VAT and capital duty are the main tax base. Special rules apply in case of capital gains and income.   FCPRs are not liable to taxes as taxation of income and capital gains is imposed to its investors. For SCRs and SUIRs) there is a corporate income tax exemption SCRs are subject to value added tax (VAT) Special rules apply. No withholding tax on dividends distributed by the FCPR (if received from foreign portfolio companies), or on capital gains realized from their redemption or disposal. Special rules apply.   More countries 1. 2. 3. 4. Source:European Commission Report of Expert Group for Venture Capital