The question under question concerns a collective asset management company which, having entered into various contracts with third parties to outsource certain management and administration functions of an alternative mutual investment fund managed by it, requested confirmation to the tax authorities regarding the fact that these services could benefit from the exemption.
For the purposes of comparability of a fund to a UCITS, it is necessary that the same – in addition to being subject to “specific state supervision” – is participated by several investors who are entitled to the benefits or bear the risk associated with the relative management. Furthermore, the return on the investment made must depend exclusively on the results of the management of the fund itself.
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