Please use this identifier to cite or link to this item: https://hdl.handle.net/10419/312198 
Year of Publication: 
2024
Series/Report no.: 
ZEW Discussion Papers No. 24-080
Publisher: 
ZEW - Leibniz-Zentrum für Europäische Wirtschaftsforschung, Mannheim
Abstract: 
This paper examines the legal consequences and assesses the economic impact of the differing tax treatment of investment funds in Portugal, Germany, and Luxembourg before and after the Allianzgi-Fonds case decision. Before the Allianzgi-Fonds case decision the Portuguese investment taxation discriminated against foreign investments by levying a withholding tax compared to domestic ones. As a result of the Allianzgi- Fonds landmark case, our paper examines whether the Portuguese CIT-exemption extended to non-resident UCITS will lead to tax neutrality treatment of investment funds in the EU. Overall, we confirm that the abolishment of the discriminatory withholding tax can considerably reduce the effective tax levels for cross-border investments. Moreover, the abolishment also diminishes the domestic investment bias. Nonetheless, the results do not confirm the achievement of neutrality.
Subjects: 
European Court of Justice
Funds
Investor
Taxation
Portugal
JEL: 
H24
H25
K34
Document Type: 
Working Paper

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