Issue 84 – Regulatory and Tax Developments in September 2011 pot

1

FUND NEWS
September 2011
Investment Fund Regulatory and Tax developments in
selected jurisdictions
Issue 84 – Regulatory and Tax
Developments in September 2011

Regulatory News

European Union

ESMA publishes updated measures
regarding Short Selling

On 29 September 2011 ESMA
published an updated list of measures
adopted by competent authorities on
short selling. This update includes
measures taken by France, Greece, Italy
and Spain.
The full list of measures is available via
the following web link:

/>p?id=7696

ESMA launches a Call for Evidence
on empty voting

On 14 September ESMA launched a
Call for Evidence on empty voting.
Currently there are no specific rules
relating to empty voting at the European
level. ESMA’s objective is to collect

Regulatory Content
European Union
ESMA publishes updated measures regarding
short selling Page 1
ESMA launches a call for evidence on empty
voting Page 1

Ireland
Fitness & Probity for directors and staff Page 2

UK
FSA issues PS 11/10 on its Transposition of the
revised UCITS Directive Page 2
FSA quarterly consultation includes minor
amendments for the operation of Authorised
Funds Page 2

Tax Content
European Union
European Commission proposes a Financial
Transaction Tax Page 3

Netherlands
New bill on reclaims of Dutch dividend
withholding tax Page 4


Poland
Proposed amendments to the tax exemption
regime applicable to EU and EEA funds Page 4

Spain
Royal Decree 1145/2011 amending the General
Regulations on tax management and inspection
actions and procedures Page 5

Switzerland
Switzerland and the UK initial tax agreement
Page 8
UK
Authorised Investment Funds amending tax
regulations published Page 8
HM Treasury confirms it will introduce a
protected cell regime for OEICs by November
2011 Page 8

Fund News – September 2011

2





information and evidence on the extent
to which empty voting practices exist in
practice within the EU and the effects
of such practices.

The Call for Evidence is available via the
following web link:
/>php?id=7819

Ireland

Fitness & Probity for directors and
staff

The Central Bank of Ireland has issued
new Fitness and Probity Standards for
all Irish regulated firms. These rules
apply to two categories of staff – Pre-
Approved Control Functions (“PCFs”)
and Controlled Functions (“CFs”).

These new rules are being introduced
on a phased basis over the next year in
order to allow for the introduction of
new internal controls and procedures.
UK

FSA issues PS 11/10 on its
Transposition of the revised UCITS
Directive

On 2 September, the Financial Services
Authority (“FSA”) issued its policy
statement explaining its transposition of
the revised UCITS Directive (“UCITS
IV”) into UK regulation. This policy
statement is relevant not only to the UK
industry but also to those firms, in the
UK and overseas, looking to passport
services whether through the cross-
border marketing of UCITS funds or
those non-UK UCITS managers seeking
to use the management company
passport to manage UK-authorised
UCITS schemes.
PS 11/10 reports on implementing the
revised directive in the UK and
summarises the feedback received to
the questions the FSA “asked” when it
issued the implementation consultation
paper of December 2010. PS 11/10

publishes the final rules that have
already been implemented by the
transposition deadline through statutory
instrument (SI 2011/1613) and the FSA
Board approved Handbook changes
(see Fund News Issue 81).
The new features of UCITS IV have
already been extensively discussed,
however, the FSA re-emphasises that
the Key Investor Information Document
(“KIID”) will be a shorter and clearer
document to help consumers compare
funds and make more informed choices
before they make their investment
decision. It reiterates that firms have
until 30 June 2012 to introduce the
KIID.
The policy statement (295 pages) is
available via this web link:


/>_10.pdf
Note that from page 37 of PS 11/10, the
document comprises the “Made rules”,
i.e. the implementing legal instrument:
UCITS IV Directive Instrument (FSA
2011/39), and, while these 257 pages
were published in July and are already
included in the updated FSA Handbook
in a wide range of places, document

FSA 2011/39 provides a useful “black
line” version showing the changes
made by the FSA across the FSA
Handbook to implement the UCITS IV
Directive.

FSA quarterly consultation includes
minor amendments for the operation
of Authorised Funds

On 7 September the FSA issued CP
11/18, its quarterly consultation paper
30, in which it proposes minor
amendments to the Rules and Guidance
in its handbook. In September the
quarterly consultation included
amendments with respect to authorised
funds set out in chapter 6.
The FSA’s quarterly CP proposes
changes for authorised funds as
follows:
 umbrella Non-UCITS retail schemes
(“NURS”) will be permitted to
combine sub-funds that operate as
FAIFs (Funds of Alternative
Investment Funds) alongside sub-
funds that are not FAIFs;
 the FSA proposed to require that
when the final sub-fund of an
umbrella ICVC is terminated such

that there is no remaining property
in the ICVC then the ICVC will be
automatically wound up. As
Fund News – September 2011

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proposed, this would prevent the
ICVC becoming an empty shell that
the Authorised Fund Manager may
then repopulate with a new range
of authorised funds;
 the FSA proposes to issue new
guidance for managers to assist
with determining if interests in
syndicated loans are eligible
investments; and
 following the implementation of
UCITS IV into the COLL
sourcebook the FSA seeks to make
two clarifications:
o which ongoing charges
figure should be published
in the short report and the
next update of the KIID
provided that it is not

misleading as an indication
of future charges; and
o that with respect to COLL
9.4.2R(1) and Documents,
that for a section 264
recognised scheme only
the KII document must be
in English in accordance
with the Directive’s
translation requirements.
The quarterly consultation is available
via the link below – the relevant Chapter
for funds is Chapter 6 (on pages 28 to
33) and the draft COLL amendments
are in Annex 6 (on pages 77 to 84) of
the 102 page document. Comments on
the proposed changes should be
provided to the FSA by 6 November
2011, details on page 33 of the CP.
/>.pdf

TAX News

European Union

European Commission proposes a
Financial Transaction Tax

On 28 September, the European
Commission published a proposed
Directive for a tax on financial
transactions.
The scope of the tax is wide, aiming at
covering transactions relating to all
types of financial instruments. The
scope covers instruments which are
negotiable on the capital market,
money-market instruments (with the
exception of instruments of payment),
units or shares in collective investment
undertakings (which include UCITS and
alternative investment funds) and OTC
derivatives agreements.
The scope of the tax is focused on
financial transactions carried out by
financial institutions acting as party to a
financial transaction, either for their own
account or for the account of other
persons, or acting in the name of a
party to the transaction.
The definition of financial institutions is
broad and essentially includes

investment firms, organised markets,
credit institutions, insurance and
reinsurance undertakings, collective
investment undertakings and their
managers, pension funds and their
managers, holding companies, financial
leasing companies, special purpose
entities, and where possible refers to
the definitions provided by the relevant
EU legislation adopted for regulatory
purposes.
Taxation will take place in the Member
State in the territory of which the

Fund News – September 2011

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establishment of a financial institution is
located, on condition that this institution
is party to the transaction, acting either
for its own account or for the account of
another person, or is acting in the name
of party to the transaction.
Two rates of tax are proposed:
 A rate of not lower than 0.01
percent on the notional amount in

respect of derivatives transactions;
and
 A rate of not lower than 0.1 percent
on the consideration paid for the
transaction (or the arm's length
market price, if higher) for all other
eligible financial transactions.

The full text of the proposed directive is
available via the following web link:

/>sources/documents/taxation/other_taxe
s/financial_sector/com(2011)594_en.pdf


Netherlands


New bill on reclaims of Dutch
dividend withholding tax

The Dutch government has published a
bill introducing a reclaim possibility for
Dutch dividend withholding tax withheld
on dividend payments to tax exempt
entities resident outside the European
Union / European Economic Area (for
Dutch, EU and EEA resident tax exempt
entities this reclaim procedure is already
applicable). Earlier, the tax authorities

announced to repay dividend
withholding tax after claims were filed
based on EU law.





Main beneficiaries of the reclaim
possibility are pension funds and
charities. Tax exempt entities that have
a function comparable to that of entities
with an exempt investment institution
or fiscal investment institution status
(articles 6a and 28 Dutch CITA) are
excluded.

This new reclaim possibility only applies
to portfolio investments. For the
definition of portfolio investments the
bill refers to the free movement of
capital as defined in article 63 of the
Treaty of the functioning of the
European Union (and not being direct
investments as referred to in article 64
of that treaty).

Furthermore, the Dutch Ministry of
Finance must have designated the
country of residence as a qualifying

country. Only countries that have
concluded a tax treaty with the
Netherlands that provides for the
exchange of information (a Tax
Information Exchange Agreement) can
qualify.

It is envisaged that this new legislation
will be in force as of 1 January 2012.

Further information re this bill (in Dutch)
is available via this link:

/>n/belastingplan-2012

For information on earlier claims follow
this link:
/>WeDo/Tax/Documents/EU-tax-flash/etf-
165.pdf



Poland

Proposed amendments to the tax
exemption regime applicable to EU
and EEA funds

The Polish Government recently
published further proposed

amendments to the Polish Corporate
Icome Tax Act.
More specifically, as an additional
condition to benefit from the exemption
regime currently applicable to foreign
investment funds, such foreign funds
will have to be managed by an entity
operating on the basis of a permission
issued by the competent financial
sector authorities of a given state.
This additional general comparability
requirement (i.e. existence of an
authorized management company) will
be imposed on all foreign funds, and
one cannot exclude that it will lead to
the exclusion of self-managed corporate
funds from the exemption regime.
In addition, it seems that the
Government intends to apply the
exemption also to close-ended funds
which do not operate on the basis of a
permission issued by the competent
financial sector authorities of a given
state but must only notify about
initiation of investment activities. To
benefit from the withholding tax
exemption in Poland such funds will
have to meet the following additional
requirements:
 such funds are close-ended funds

 investment certificates (units) in a
given fund are not offered publically
(traded on the stock exchange) or
traded on any regulated market or
other multilateral trading facilities
 in case investment certificates can
be acquired by individuals, such
Fund News – September 2011

5




 individual purchases must have a
minimum value of EUR 40,000.
The proposed amendments are
currently being discussed at
Government level and, if accepted, will
be submitted for consideration to the
Parliament. These proposed provisions
further depart from the EU
Commissions' standpoint (formal
request dated 11 June) according to
which current legislation, by introducing
numerous exemption requirements,
remains discriminatory with respect to
foreign funds.

Spain

Royal Decree 1145/2011 amending
the General Regulations on tax
management and inspection actions

and procedures

Simplification of formal obligations in
connection with investors in fixed-
income financial instruments
(Government and Qualifying Public
Debt). Modification of the obligation to
obtain a Spanish Tax Identification
Number.
On 30 July 2011 the Official State
Gazette published Royal Decree
1145/2011, dated 29 July, (“RT
1145/2011”), which amends the
General Regulations on tax
management and inspection actions
and procedures, approved by Royal
Decree 1065/2007, dated 27 July (“RD
1065/2007”).
As described in the Preamble, RD
1145/2011 introduces a simplification of
the reporting obligations for non-
resident investors of fixed-income
financial instruments.
RD 1145/2011 also simplifies the
obligations for Spanish Resident
Corporate Income Tax (“CIT”) taxpayers
in respect of investments of specific
fixed-rate financial instruments and
clears up certain doubts in connection
with the obligation for non-resident

investors to obtain a Spanish Tax
Identification Number (“TIN”) when
investing in securities.

Modification of information duties of
non-resident investors

Royal Legislative Decree 2/2008, dated
21 April, which sets forth measures to
boost economic activity, extended the


scope of the exemption of the Non-
Resident Income Tax (“NRIT”) Law for
Government Debt and other financial
instruments to all non-resident investors
regardless of their country of residence
(including investors which are resident
in jurisdictions considered tax havens
for tax purposes).
On the other hand, Law 4/2008, dated
23 December, which abolishes Net
Wealth Tax, eliminated the obligation of
providing information on income derived
from Government and private Debt
issued in accordance with Law 13/1985,
dated 25 May, on investment ratios,
equity and information duties of
financial intermediaries (hereinafter,
“Qualified Corporate Debt”) obtained by

non-resident investors without a
permanent establishment in Spain.
However, until the recently approved
RD 1145/2011, no Regulations
developing amendments introduced by
Law 4/2008 were approved. In this
regard, in accordance with the tax
rulings issued by the General
Directorate of Taxation (“Dirección
General de Tributos”), dated 20 January
2009, information duties relating to the
identity of beneficial owners as laid
down in RD 1285/1991, dated 2 August,
and article 44 of RD 1065/2007
remained applicable in order to apply
the NRIT exemption to income derived
from Government Debt and Qualified
Corporate Debt obtained by non-
resident investors acting without a
permanent establishment in Spain. As a
result, until the recently approved RD
1145/2011 the onerous information
obligations applicable in respect of non-
resident investors that existed prior to
the enactment of Law 4/2008 were
maintained.
Fund News – September 2011

6

Tax regime applicable as of 31 July
2011

RD 1145/2011 has developed the
amendments introduced by Royal
Legislative Decree 2/2008 and Law
4/2008, establishing and simplifying the
procedure for paying Government and
Qualified Corporate Debt. In this sense,
Article 44 of RD 1065/2006 has been
amended, unifying procedures for
Government and Qualified Corporate
Debt.
The new procedure established by
RD 1145/2011 can be summarized
as follows:
 It is no longer obligatory to
individually identify the
beneficiaries of interest deriving
from debt securities (both
Government and Qualified
Corporate Debt).
 The current individual identification
procedure is replaced with a
certificate issued by:
(i) In the case of Government
Debt securities: Spanish
management entities and
securities clearing and

settlement entities resident
outside of Spain which have
signed an agreement with a
Spanish securities clearing and
settlement entity.
(ii) In the case of Qualified
Corporate Debt initially
registered with a Spanish
clearing and settlement
entity (Iberclear): Participant
entities in Iberclear or non-
Spanish securities clearing and
settlement entities which have
signed an agreement with
Iberclear, or
(iii) In the case of Qualified
Corporate Debt initially
registered with a foreign
clearing and settlement
entity (e.g. Euroclear,
Clearstream, DTC): The
paying agent designated by the
issuer.
 The certificate, which must follow
the official form attached to RD
1145/2011, exclusively includes (i)
the securities identification; (ii) the
total amount of the return derived
from the relevant securities; (iii) the
amount of the return corresponding

to individuals subject to the
Spanish Personal Income Tax (PIT),
and (iv) the total amount of the
return that may be paid free of
withholding tax in Spain (i.e. the
part of the total amount of the
return of the relevant securities
paid to investors who are not
Spanish PIT taxpayers).

 In case of Qualified Corporate
Debt initially registered with a
foreign clearing and settlement
entity (e.g. Euroclear, Clearstream,
DTC), the statement issued by the
paying agent must only include (i)
the securities identification; and (ii)
the total amount of the return
corresponding to each foreign
clearing and settlement entity (i.e.
there is no requirement to include
the amount attributable to Spanish
PIT taxpayers).

 The referred certificate does not
replace other general information
duties set forth in the Spanish Tax
Law in connection with debt
issuers or depositaries with regard
to PIT and CIT taxpayers or NRIT

taxpayers with a permanent
establishment in Spain investing in
Government or Corporate Debt.
Payment procedure applicable as of
31 July 2011
RD 1145/2011 establishes a double
payment procedure:

 The above referred certificate must
be filed on the business day prior to
the date of payment of interest.
This certificate can be filed
electronically. Once this
information is provided, interest
can be paid gross.
 In case the return is not filed within
this deadline, the issuer or the
paying agent will carry out the
relevant withholding (currently at
a19% rate), and pay the net
amount.

Nevertheless, the issuer or paying
agent will refund the amounts initially
withheld providing the certificate is filed
(i) within the following 30 days as of the
payment date of interest derived from
Government Debt securities or (ii) as of
the tenth day of the month following
that in which the interest resulting from

the Qualified Corporate Debt becomes
due.

Amendments affecting CIT taxpayers
and non-residents with a permanent
establishment in Spain

RD 1145/2011 has also simplified the
obligations for CIT and NRIT taxpayers
with a permanent establishment in
Spain investing in Government and
Qualified Corporate Debt.
The income obtained by these
taxpayers will be subject to the same
procedure explained for non-resident
investors, thus simplifying their
information duties.

Fund News – September 2011

7


Amendments regarding the
obligation for non-resident investors
to obtain a Spanish Tax Identification
Number when investing in securities

RD 1145/2011 has also modified RD
1065/2007, introducing certain

clarifications in connection with the
obligation for non-resident investors
without a permanent establishment in
Spain to obtain a TIN when investing in
Spanish securities.
In this sense, it is not necessary to
obtain a TIN in the following cases:
 When acquiring or purchasing
securities represented by stocks or
book entries located in Spain, or
acquiring financial assets with an
implicit return, provided such
transactions are carried out by
means of a securities account held
by a non-resident without a
permanent establishment in Spain.
 In case of the subscription,
acquisition, reimbursement or
transfer of shares in Spanish
collective investment institutions or
collective investment schemes
commercialized in Spain under Law
35/2003, of 4 November, provided
these transactions are carried out
by means of a securities account
held by a non-resident without a
permanent establishment in Spain.
It should be noted that RD 1145/2011
also eliminates the obligation for non
residents operating with assets or

liabilities account or shares account to
obtain a TIN. As a result, the number of
cases in which a TIN is not required has
been increased (e.g. loans or credits).
In order to apply this exemption from
the obligation to obtain a TIN, the non-
resident must evidence its status by
providing: (i) a tax residence certificate
issued by the
relevant tax authorities; or
(ii) a tax residence declaration using the
Form approved by the Spanish
Authorities.

Enactment
RD 1145/2011 came into force on the
day following its publication in the
Official State Gazette (31st July 2011),
and is applicable to all interest
payments, redemptions or
reimbursements of securities issued at
discount or segregated, made as from
31st July. As a result, it will be
applicable not only to debt issues made
from this date onwards, but also to
those still “alive” on the referred date.

Observations
RD 1145/2011 changes the information
duties of non-resident investors, which

also applies to CIT and PIT taxpayers.
The main amendments introduced may
be summarized as follows:
 Elimination of the specific
obligation for the issuer to identify
non-resident investors acquiring
Government Debt securities or
Qualified Corporate Debt. This
obligation is also eliminated for CIT
taxpayers as well as for NRIT
taxpayers operating through a
permanent establishment in Spain.
 Issuers will also not be obliged to
identify PIT taxpayers investing in
Spanish Government Debt
securities or Qualified Corporate
Debt. In this sense, it will only be
necessary to identify the total
amount of the income
corresponding to such PIT
taxpayers. Nevertheless, in
principle, this does not involve a
change in the general withholding
tax regime applicable to Spanish
tax resident individuals nor the
general identification and
information duties regarding
financial institutions taking part in
these transactions.
Furthermore, in the case of

Qualified Corporate Debt initially
registered with a foreign clearing
and settlement entity (e.g.
Euroclear, Clearstream, DTC), it will
only be necessary to identify the
total amount of the income
corresponding to each foreign
entity that manages the clearing
and settlement of securities (that
is, it shall not be necessary to
include the information regarding
the income obtained by Spanish
PIT taxpayers).
 A single information procedure is
established together with a simple
and flexible payment system which
reduces the administrative
requirements for issuers,
depositaries and investors.
 Unification of the different
procedures and systems, creating a
single procedure and payment
system for investments in both
Government Debt securities as
well as Qualified Corporate Debt
and applicable to both non-resident
investors and CIT taxpayers.
 No reference is made in RD
1145/2011 in connection with a
“beneficial owner” test in case of

certain pass-through non-resident
institutional investors. This issue
may still be relevant and
outstanding in those cases in
which, under the new Regulation,
the total amount of the income
obtained by Spanish PIT taxpayers
must be identified.
 Non-resident investors operating in
Spain without a permanent
establishment will not be obliged to
obtain a TIN when investing in
Fund News – September 2011

8





 Spanish securities or in Spanish
Collective Investment Institutions,
provided these transactions are
made by means of a securities
account and the non-resident
investor provides evidence of its
non-resident status. The procedure
for certifying the non-resident
status is pending approval.
Apparently, this new Regulation

extends the exemption for
obtaining a TIN to other loan and
credit transactions.
 RD 1145/2011 came into force on
31st July 2011. As a result, the
amended information requirements
and TIN obligations are fully
applicable not only to debt issues
made from this date onwards, but
also to those still “alive” on the
referred date.

Switzerland

Switzerland and the UK initial tax
agreement

On 24 August 2011, British and Swiss
negotiators initialled a tax agreement in
order to resolve outstanding tax issues
between the two countries. This tax
agreement is largely the same as the
agreement between Switzerland and
Germany signed by the Finance
Ministers of both countries in
September.
Under this agreement, persons resident
in the United Kingdom can
retrospectively tax their existing banking
relationships in Switzerland either by

making a one-off tax payment or by
disclosing their accounts. For the future,
investment income and capital gains of
British investors in Switzerland will be
subject to a final withholding tax, and
the proceeds of this will be transferred
to the British authorities by Switzerland.
The next step of the negotiations is the
signing of the agreement by both
countries’ governments and its approval
by the parliaments of both countries.
This agreement should enter into force
at the start of 2013.
More information can be found on the
Federal Authorities of the Swiss
Confederation website (www.admin.ch)
or on the Federal Department of
Finance website (www.efd.admin.ch).








UK

Authorised Investment Funds
amending tax regulations published

The final version of The Authorised
Investment Funds (Tax) (Amendment
No.2) Regulations 2011 have been
published and come into force on 1
October 2011. The amendments align
the treatment of UK funds with recent
changes made to the offshore funds
regulations, with regards to the genuine
diversity of ownership condition and
index tracking funds.

Genuine Diversity of Ownership
condition

The genuine diversity of ownership
(“GDO”) condition is a requirement of a
number of tax-beneficial regimes
established in recent years, including
the tax regimes for: Qualified Investor
Schemes; Property AIFs; Tax Elected
Funds; and to provide certainty that
diversely owned authorised funds are
not taxable on trading profits.
The GDO test previously only applied to
a single fund or feeder fund into a
property AIF, but in the case where
funds are invested in other funds, the
new regulations allow a ‘look-through’
to the underlying fund to substantiate

the test.

Index-tracking funds

Provided the requirements of
Regulation 14ZD are met for a UK
authorised index tracking fund, offshore
income gains under regulation 17 of the
offshore funds regulations do not arise
if the UK fund invests non-reporting
offshore funds.
Fund News – September 2011

9


Regulation 14ZD includes a requirement
that the UK fund replicates the capital
and income returns of the index ‘as
closely as practicable’. This should
reduce the administrative burden for
index-tracking authorised funds.
The regulations are contained in
Statutory Instrument 2011/2192 (4
pages) which is available via this web
link:
/>2192/made

HM Treasury confirms it will
introduce a protected cell regime for

OEICs by November 2011

In September the Government
confirmed that it will introduce a
protected cell regime (“PCR”) for UK
open ended investment companies
(“OEICs”) by November 2011. The
announcement was part of Mark
Hoban, Financial Secretary to the
Treasury’s wider “New Regulation 2”
announcements. The introduction of a
PCR for OEICs is part of the measures
to facilitate the competitiveness of UK
asset management and to protect
investors in umbrella OEICs from the
risk of contagion should a sub-fund in an
umbrella OEIC collapse.
The introduction of a PCR for UK OEICs
has been under consideration for
several years and, with the advent of
UCITS IV, is an important feature for the
UK to include and reflects that sub-fund
asset ring-fencing already exists in other
jurisdictions. The availability of a PCR
may influence the location of the
master funds under UCITS IV.
The impact assessment has not yet
been published. However, one area of
concern is that prior discussion papers
have envisaged that the requirements a

PCR will be imposed on both new and
existing OEICs. If the PCR is
compulsory of all OEICs, the period that
will be permitted for existing OEICs to
adopt the PCR will need to allow
sufficient time in which the OEIC’s
supplier contractual arrangements can
be revised where these would be
impacted by the changes arising from
the PCR.
The statement (6 pages) is available via
the web link below includes the PCR
proposal as the second bullet on page
one with a summary on the final page:

-
treasury.gov.uk/d/hmt_new_regulation_j
undec11.pdf

Fund News – September 2011

10



Contact us
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Senior Manager
T: + 352 22 5151 7369
E:
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Partner
T: + 352 22 5151 7319
E:
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Publications

Tax
Georges Bock
Partner
T: + 352 22 5151 5522

E:






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Vincent Heymans
Partner
T: +352 22 5151 7917
E:





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timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such
information without appropriate professional advice after a thorough examination of the particular situation.

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