International Tax Issues in Relation to Cross-Border Investment Funds

The article will analyse the main international tax issues that arise with regard to cross-border investment funds, such as the entitlement to treaty benefits, the residence for tax purposes and the existence of a permanent establishment in the country in which the investment is made if certain activities are carried out therein. Specific fours shall be dedicated, inter alia, to the international tax issues connected with the provisions of the EU directive on Alternative Investment Funds.