Investment entity’ means:

(a)   an investment fund or a real estate investment vehicle;

(b)   an entity that is at least 95 % owned, directly or indirectly, by an entity referred to in point (a) or through one or more such entities, and that operates exclusively or almost exclusively to hold assets or invest funds for their benefit;

(c)   an entity that is owned at a minimum of 85 % by an entity referred to in point (a) provided that substantially all of its income is derived from dividends or equity gains or losses that are excluded from the computation of the qualifying income for the purpose of this Directive.

 

Investment fund’ means an entity or arrangement that meets the following conditions:

(a)   it is designed to pool financial or non-financial assets from a number of mostly non-related investors;

(b)   it invests in accordance with a defined investment policy;

(c)   it allows investors to reduce transaction, research and analytical costs or to spread risk collectively;

(d)   it is primarily designed to generate investment income or gains, or protection against a particular or general event or outcome;

(e)   its investors have a right to return from the assets of the fund or income earned on those assets, based on the contribution they made;

(f)    it, or its management, is subject to the regulatory regime for investment funds in the jurisdiction in which it is established or managed; and

(g)   it is managed by investment fund management professionals on behalf of the investors.

 

Real estate investment vehicle’ means a widely held entity that holds predominantly immovable property and that is subject to a single level of taxation, either in its hands or in the hands of its interest holders, with at most one year of deferral.

 

 

Copyright – internationaltaxplaza.info

 

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