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.
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| Country | Venture capital Vehicles | Investment Target |
Tax Base | Person to be taxed |
Tax Rate | Other | Useful Link |
|---|---|---|---|---|---|---|---|
| Ireland | Regulated Investment Funds: - Unit Trust (collective investment fund) - VCC (variable capital investment company) - Investment Limited partnerships - Common Contractual Funds - Typically Professional Investor or Qualifying Investor Funds |
cross-border investments | Capital gains, dividends, interest. |
Holding companies are treated as opaque. In case of transparent entities there tax is imposed at the level of the partners.DTCs regulations are applied. |
Capital gains tax: Dividends: No subscription tax, no Net Wealth Tax, no Capital Duty. Dividends/interest paid to non residents: Capital gains paid to non residents: |
No thin capitalization rules are applicable. The EU Savings Directive is not applicable. Professional Investor and Qualifying Investor Funds are tax exempted.No tax is withheld at source. They qualifie as a taxable person for VAT purposes. A partnership qualifies as a taxable person for VAT purposes.
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| Belgium | - Public and Private PRICAF / PRIVAK (closed ended investment funds in corporate form). - Public PRIFONDS (closed ended transparent fund investment fund). |
Cross-border investments | Dividends, |
PRICAF is treated as opaque.(tax is imposed on the company). A PRIFONDS is transparent for tax purposes (tax is imposed on individuals) |
PRICAF: normal corporate tax rate of 33.99% imposed on a reduced tax base. Dividend: Partial exemption on withholding tax is applied. Capital gains: |
For dividends paid by the investment company, the EU Savings (Tax) Directive is not applicable. No Belgian withholding tax is applicable on investment income earned by the PRICAF, except for dividends received from Belgian resident companies. No Belgian withholding tax on distributions coming from a transparent fund (PRIFONDS). |
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| Luxemburg | -SICAR(Société d’Investissement en Capital à Risque). 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. |
cross-border investments. |
corporate entity, or individuals (in tax transparent partnership – i.e. S.C.S.) | SOPARFI and SICAR in the legal form of corporate entity (S.A., Sarl or SCA) are subject to corporate income taxes ( 28,59% for Luxembourg city). Potential exemption for dividends, liquidation surplus and capital gains. -SIF is a tax exempt fund vehicle (only fixed registration fee of EUR 75 and a subscription tax are payable. |
SOPARFI: SICAR:Dividends, liquidation surplus, capital gains and interest are not subject to any WHT.No subscription tax nor Net Wealth Tax. SIF are WHT exempt. |
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| more countries shall follow soon |
Source:European Commission Report of Expert Group for Venture Capital