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A consultant asks whether losses can be offset in a Luxembourg fund investing in Russia via a lucrative or paid transfer. The DGT states that gratuitous transfers do not allow loss offset and warns of simulation risks if the sole purpose is fiscal.
Question posed: Possibility of recognizing such losses in Personal Income Tax through onerous or gratuitous transfer.
In the event of a gratuitous transfer of units in collective investment institutions, capital losses shall not be recognized for Personal Income Tax purposes pursuant to Article 33.5.c) of the Personal Income Tax Law. For onerous transfers, the gain or loss is determined by the difference between the acquisition value and the transfer value (net asset value or equity). If the sole purpose of the transaction is to obtain a tax loss, the rules regarding simulation and conflict of laws under the General Tax Law could apply.
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