Luxembourg: Updated guidance on certificates of residence for collective investment funds

Updated list of income tax treaties for which it is possible to obtain certificates of residence

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January 21, 2025

Circular L.G.-A. No. 61 (dated December 24, 2024, and published December 27, 2024) replaces Circular L.G.-A. No. 61 (dated December 8, 2017) which provides guidance on the granting of a certificate of residence (CoTR) to collective investment funds.

There were no changes regarding the conditions to request or obtain a CoTR, but the list of income tax treaties for which it is possible (or not) to obtain a CoTR has been updated as follows for an investment company with variable capital (SICAV) or with fixed capital (SICAF):

  • New income tax treaty for which a CoTR can be delivered: Botswana, Cyprus, Ethiopia, France, Hungary, Kosovo, Rwanda, and United Kingdom
  • New income tax treaty for which a CoTR cannot be delivered: Senegal

Read a January 2025 report prepared by the KPMG member firm in Luxembourg

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