|Practical use||- Hedge funds
- Private equity and venture capital
- Real estate transactions
|Applicable legislation||Law of 13 February 2007 (“SIF Law”)|
|Eligible investors||Well-informed investors|
Any kind of assets can be integrated or any type of investment strategies may be pursued.
|Risk diversification requirements||Risk diversification requirements are
defined by CSSF Circular n° 07/309.
Such requirements are less stringent
than the ones applicable to UCITS
In particular, a SIF is not allowed to
invest more than 30% of its net
assets in securities of the same type
|Legal Form||- FCP
- SICAV (SA, Sàrl, SCA, SCoSA)
- SICAF (SA, Sàrl, SCA, SCoSA)
The entities may be open-ended or
|Capital requirements||EUR 1,250,000 to be reached within
12 months from the approval by the
|Net asset value (NAV) calculation and redemption policy||At least once a year for reporting
|Corporate income tax||No corporate income tax|
|Subscription tax||- Rate: 0.01% of the NAV
- Tax exemptions: certain money market and pension funds or SIFs investing in other
funds which are already subject to subscription tax.
|Wealth tax||No wealth tax.|
|Withholding tax on dividends / interests and capital gains||Not subject to withholding tax except
if EU Savings Directive applies.
|Benefit from double tax treaty network||- Limited to funds set-up in the form of a SICAV / SICAF only.
- Limited to certain double tax treaties.
|Benefit from the EU Parent Subsidiary Directive||No|
|Authorisation and supervision by the CSSF||Yes|
|Possibility of listing||Yes|
|European passport||No unless it falls under the scope of the full AIFMD regime|
|Thin capitalization rules (debt-to-equity ratio)||No debt-to-equity ratio.|
|Required Luxembourg service providers||- Management Company in case
of an FCP
- Depositary institution
- Administrative agent
- Registrar and Transfer Agent