Selected Aspects of the Architecture of Foreign Investment Fund Regimes
TAXING OFFSHORE INVESTMENT INCOME: A COMPARATIVE REVIEW OF STRUCTURAL ISSUES, pp. 145-156, John Prebble, ed., Fiscal Publications, 2006
12 Pages Posted: 13 May 2010 Last revised: 15 Apr 2015
Date Written: 2006
Abstract
This is a chapter of a book on foreign investment fund regimes. Most features of foreign investment fund regimes fit reasonably neatly into the analytical framework of definition, boundaries, scope, exceptions, and calculation of income, topics that are dealt with in other chapters of the book. This chapter comprises a miscellany, ranging from general observations that are relevant to most foreign investment fund regimes to discussion of specific features that only some regimes have adopted.
Foreign investment fund regimes are closely related to controlled foreign company regimes. Most foreign investment fund regimes focus on their domestic taxpayers and take the funds that these taxpayers invest in as they are. If a fund provides enough information for domestic taxpayers to make branch equivalent calculations of income, so much the better. If not, the taxpayer’s income is assessed according to one of a number of surrogate methods. Foreign investment fund regimes often include rules to ensure that investors’ income does not suffer double taxation.
Keywords: Foreign investment fund regimes, anti-avoidance
JEL Classification: K33, K34
Suggested Citation: Suggested Citation