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The Tax Treatment of CIVs and REITs comprises the proceedings of a conference held by the Amsterdam Centre for Tax Law (ACTL) of the University of Amsterdam on 2 November 2012. The book provides a unique and current overview of the tax issues that play a role in the cross-border operation of collective investment vehicles (CIVs) and real estate investment trusts (REITs). Typically, these investment funds function well in a domestic context, where the investors, the fund and the investments are all located in one state. In an international context, however, interesting issues arise, such as questions on the proper allocation of taxing rights, beneficial ownership and non-discrimination. These and other issues are addressed in this book.
The book starts with the 2008 and 2010 updates to the OECD Model Tax Convention, adopting the OECD CIV and OECD REIT reports with a view on policymakers and practice. In addition, it places the treatment of CIVs and REITs in an EU tax law perspective. Finally, future developments are also discussed, including the impact of the Undertakings for Collective Investment in Transferable Securities (UCITS) Directives IV and V and the Alternative Investment Fund Managers Directive (AIFMD), from both a direct tax and an indirect tax perspective.
Collective investment is of increasing importance in a society with a proportional rise in the ageing population, as a means for the public to save for later. The Tax Treatment of CIVs and REITs provides a valuable overview of the international tax issues that the CIV and REIT vehicles encounter in an international context.
This book is of interest to tax practitioners, multinational businesses, policymakers, tax administrators, judges and academics.