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Tax gap analysis

Aside from our regulatory services, Deloitte will also assist funds managers and alternative investment funds to anticipate the tax implications in connection with the requirements and opportunities introduced by the Alternative Investment Fund Managers Directive.

Because tax may significantly impact the overall performance of the fund and consequently the carry, it is paramount to have an early access to accurate tax planning. Deloitte is looking forward to helping you find tax-efficient solutions in line with your business model as well as complying with the AIFMD.

How Deloitte can help?

Our services look to assist funds managers and alternative investment funds with the various tax implications pertaining directly or indirectly with the AIFMD but also more broadly with all tax implications in relation to the alternative funds industry.

Thus, our tax services are covering tax implications at the level of the vehicle itself and its managers whatever their locations but also with respect to the investors in the fund and investments targeted.

Our wide range of services therefore inter alia include the following:

  • Alternative investment funds: selection of most tax-efficient vehicle and related tax structuring if needed;
  • Offshore to onshore: tax planning and assistance with respect to offshore alternative investment funds or fund managers willing to move onshore and set-up their operations in Luxembourg;
  • Fund managers: tax planning for alternative investment fund managers and optimisation of carried-interest structures depending on their location;
  • Cross-border fund management: identification of permanent establishment aspects for fund managers managing alternative investment funds in various jurisdictions;
  • Transfer pricing: analysis of transfer pricing considerations for fund structures (e.g. management fees, performance fees, sub-delegation, etc.) within a cross-border context;
  • Tax compliance: assistance with respect to the tax compliance of Luxembourg funds or managers vehicles;
  • Reclaim of the foreign withholding tax suffered at source on either dividends and interest received.


  • Benjamin Collette
    Partner - EMEA AIFMD Leader
  • Raymond Krawczykowski
    Partner - Tax Leader
  • David Capocci
    Partner - Tax - Mergers & Acquisitions
  • Christophe Diricks
    Partner - Tax - Mergers & Acquisitions



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