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Advices for Venture and Startup

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.

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Country Venture capital Vehicles Investment
Target
Tax Base Person
to be taxed
Tax Rate Other Useful Link
Italy Fondo Chiuso (close-ended fund and has not legal personality). Also corporate entities may be established.

n.a.

Yearly yield. The Fund (Fondo Chiuso). Distributions from the Fondo Chiuso to foreign investors are not subject to any further taxation (in particular, no withholding tax applies 12.5% tax on the yearly yield. Special rules apply.

1) The Fondo Chiuso is fully exempt from the standard income taxes if all the investors are 'qualified' foreign investors. This means that the State of residence of the foreign investor can exchange information with Italy regarding the above investor. Special rules apply.

2) It is not certain whether the Fondo Chiuso is entitled to treaty benefits

 
Greece Capital Holding Companies (EKES); Non listed companies. Special rules apply. Dividends. Not clear about capital gains. EKES The income tax rate is 20%. Special rules apply.    
Spain Venture Capital Companies (VCCs) and
Venture Capital Funds (VCFs)(the latter have no legal personality)
Domestic and cross-border investments in Venture Capital.

Capital gains, Dividends.

Special rules apply.

Venture Capital companies and Funds

99% tax relief of the burden attributable to capital gains.

the rest of the income received by VCCs and VCFs will be taxed at the standard Corporate Income Tax rate of 30%

In the event that the beneficial of income is a Non-resident without a permanent establishment, the income is not regarded as coming from Spanish source and thus, it will not be subject to Spanish taxation.  

More countries 1. 2. 3. 4.

Source:European Commission Report of Expert Group for Venture Capital

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