Key Features
Target investors | Retail |
Up-front registration |
❌ |
Taxation mechanism |
Asset based |
Annual reporting |
✅ |
Main features
The "Equity Portion" needs to be calculated and reported as of 1st January of each fiscal year in order to define the classification of the sub fund in which Norwegian investors are investing in.
As of each distribution date, the above equity ratio will be used in order to determine the taxation rate of the investor (distribution considered as dividends, interest or proportionally allocated following the Equity Portion).
Distribution breakdowns need to be provided to Norwegian investors (income vs capital gains).
As of each redemption date, the equity ratio applicable to the investor will be determined as an average between the ratio of the year of subscription and the ratio of the year of redemption.
Benefits of the regime
Investors' taxation will depend on the ratio between bonds and shares.If the fund doesn’t provide this information, all distributions will be treated as interest.
Scope of services
Christian Heinz
Tax Partner, Global Tax Compliance Leader, PwC Luxembourg
Tel: +352 621 33 2247