International tax advice

List of Double Tax Treaties applicable to SICAV/SICAF/FIS

These countries have expressed their consent to consider SICAV/SICAF/FIS as "Resident” (or on the interpretation of the Double Tax Treaty is self explanatory).

As regards Spain, only the income coming from OPC, duly authorized by the competent authority from each State and commercialized in the other State after having met the conditions established for that purpose in the section VIII from the directive 85/611/CEE from the "Conseil" of 20 December 1985 are covered by the arrangements from the fiscal convention of 3 June 1986 concluded between Spain and Luxembourg.

As for the countries with which the Grand Duchy of Luxembourg has concluded a double tax treaty, but have not pointed out if the SICAV or SIVAF could claim the convention profit, notably

It is up to the "Administration des contributions directes, bureau d'imposition Sociétés 6, L-2982 Luxembourg" to deliver the certificates of residence on a specific form basis.

The "Administration de l'enregistrement et des domaines" is not entitled  to issue certificates of residence.

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