International tax structuring
Both the Dutch and Luxembourgian tax laws facilitate attractive opportunities for the tax structuring of international companies. For example the establishment of a group with combined holding structures may trigger high tax savings. Provided they support a clear business objective, such as business model optimizations, acquisitions and restructurings, distribution of profits to stakeholders, intercompany financing flows or the implementation of new innovative financial concepts. Our team has a proven track record of tax structuring in three continents, assisting with obtaining rulings from tax authorities (when possible), implementing and monitoring structures.
In particular for investors which invest through a legal entity (corporate investors), investments in or through a Luxembourgian fund or company may trigger attractive tax savings. One example is the establishment of a Luxembourgian holding structure through which certain (financial) business assets are held. Also, the use of a combined holding structure creates many tax efficient structuring possibilities.
Individuals (not investing through a legal entity)
For investors which do not invest through a legal entity (individuals), investments in or through a Luxembourgian fund provide various opportunities for obtaining a favourable treatment of taxable income, to th extent is is channelled through Luxembourg. In some cases the benefits may match those of applying local transparent investment vehicles. Also, the Luxembourgian regulatory framework differs to some extent from Dutch or other frameworks. It results in a broader range of tax efficient structuring possibilities.