The document discusses various offshore tax efficient vehicles for pooling pension and investment assets, including common contractual funds (CCFs) in Ireland, fonds commun de placement (FCPs) in Luxembourg, and funds for joint account (FGRs) in the Netherlands. These pooling vehicles allow participating funds to realize economies of scale while providing tax transparency or neutrality. Recent developments have expanded the available vehicles and jurisdictions to include specialized investment funds in Luxembourg, funds of alternative funds in the UK, and institutional collective investment schemes in Belgium. Key considerations for these cross-border pooling vehicles include regulatory approval, tax treatment, and investment restrictions across jurisdictions.
With the onset of higher personal tax rates, more complex rules on the tax deductibility of interest and an election round the corner, now is the time to be thinking about structuring your tax affairs.
BDO ran a seminar for private equity executives that demonstrated:
- How to structure your fund
- How to plan during the life of your fund
- Latest techniques for structuring transactions
- Minimising VAT leakage
Find out more in the slides of the presentation.
Dubai Conference - Legal and Regulatory UpdateBishr Shiblaq
This seminar gave an update on the Luxembourg UCITS framework, addressed the Alternative Investment Fund Managers Directive (AIFMD), provided an update on the tax-treaty network with a particular focus on Turkey and India as well as present practical cases of recent Shari’ah-compliant transactions and updates on the existing legal framework.
This powerpoint describes the advantages for choosing Luxembourg as your prime location in Europe for your cross border business, alternative investments and wealth management needs. Luxembourg is a respected juridisction in the fund industry with new market niches gaining strategic importante like IT, IP, Logistics.
Keywords: Luxembourg, SOPARFI, SIF, SICAR, SPF, UCITS, Alternative Investments, Private Equity, Venture Capital, Real Estate, REIF, Funds, Hedge Funds, Securitization, SPV´s, Holdings, International Tax planning, Tax Optimization, Wealth Management, Private Banking, Start Ups, Intelectual Property
With the onset of higher personal tax rates, more complex rules on the tax deductibility of interest and an election round the corner, now is the time to be thinking about structuring your tax affairs.
BDO ran a seminar for private equity executives that demonstrated:
- How to structure your fund
- How to plan during the life of your fund
- Latest techniques for structuring transactions
- Minimising VAT leakage
Find out more in the slides of the presentation.
Dubai Conference - Legal and Regulatory UpdateBishr Shiblaq
This seminar gave an update on the Luxembourg UCITS framework, addressed the Alternative Investment Fund Managers Directive (AIFMD), provided an update on the tax-treaty network with a particular focus on Turkey and India as well as present practical cases of recent Shari’ah-compliant transactions and updates on the existing legal framework.
This powerpoint describes the advantages for choosing Luxembourg as your prime location in Europe for your cross border business, alternative investments and wealth management needs. Luxembourg is a respected juridisction in the fund industry with new market niches gaining strategic importante like IT, IP, Logistics.
Keywords: Luxembourg, SOPARFI, SIF, SICAR, SPF, UCITS, Alternative Investments, Private Equity, Venture Capital, Real Estate, REIF, Funds, Hedge Funds, Securitization, SPV´s, Holdings, International Tax planning, Tax Optimization, Wealth Management, Private Banking, Start Ups, Intelectual Property
Your guide to Private Equity in Luxembourg by the Luxembourg Private Equity & Venture Capital Association. (reprinted in 2017 with membership figures updated)
Substance as an important element of tax planning and global trends in exchange of information.
CONTENT
-Information exchange: general facts.
-AEOI: brief chronology.
-AEOI: general ideas.
-AEOI: scheme.
-AEOI: specifics.
-Practical example: Cyprus.
-What is “substance” and where does it come from?
-Today`s substance requirements.
-Actions and measures, indicating “substance”.
-Issues to be considered during the obtainment of Cyprus tax residency certificate.
-Questions asked by tax authorities investigating into substance over form.
MCI CLT Dutch Holding Structures EN (2021.03)Martin Kraeter
The various options of the Dutch Corporate Law with regards to Holding Structures. Reflecting on:
Dutch Participation (Deelnemingsvrijstelling)
Holding Subsidiaries
Tax Treaty Network
EU Withholding Tax Exemption
Dutch Finance Company (DFC)
Dutch Cooperative (DCOOP)
Stichting & STAK
Hybrid Holding
Eversheds CREATE Workshop #1: Real estate holding structuresEversheds Sutherland
Corporate Real Estate Academy Training at Eversheds (CREATE) is a series of workshops designed to further your knowledge of indirect real estate and corporatised real estate transactions.
CREATE Workshop #1: Real Estate Holding Structures explored:
• typical structures used for holding real estate and real estate joint ventures
• why each structure is used and by whom
• trends and how the status quo is changing
Future of treaty formed holding companies and preferential Harm J. Oortwijn
Past present and future developments in holding and preferential tax regimes - what once was appropriate is now perceived inappropriate... and the perception continues to evolve!
Table overview of essential facts and requirements for setting up investor funds / hedge funds in the low tax EU jurisdiction of Malta.
* Collective Investment Schemes | Hedge Fund | Mutual Fund | AIFMD | PIFs | Alternative Investment Schemes
Automatic exchange of information (AEOI) - November 2016nztaxpolicy
Presentation delivered in November 2016 (Wellington - 4th November, Auckland - 9th November, webinar - 18th November) aimed at financial institutions and covered the practical implementation and technical issues for the Common Reporting Standard.
Ireland is an advantageous location for holding companies, due to:
- Favourable tax treatment of dividend income;
- No Withholding Tax on dividends from Irish Holding Company to EU / tax treaty countries;
- No Capital Gains Tax on disposal of shareholdings in subsidiaries;
- Favourable tax regime for R&D / intangibles;
- Tax deductions for interest on borrowings;
- Favourable Withholding Tax regime for interest and royalty payments
- & more...
Ireland is an advantageous location for holding companies, due to:
- Favourable tax treatment of dividend income;
- No Withholding Tax on dividends from Irish Holding Company to EU / tax treaty countries;
- No Capital Gains Tax on disposal of shareholdings in subsidiaries;
- Favourable tax regime for R&D / intangibles;
- Tax deductions for interest on borrowings;
- Favourable Withholding Tax regime for interest and royalty payments
- & more...
Presentation. Are you the beneficial owner of the income? And is substance adequate? How much substance is need? Cyprus as a case study. Automatic Exchange of Information. Christos Theophilou - Taxatelier Ltd, Cyprus.
Your guide to Private Equity in Luxembourg by the Luxembourg Private Equity & Venture Capital Association. (reprinted in 2017 with membership figures updated)
Substance as an important element of tax planning and global trends in exchange of information.
CONTENT
-Information exchange: general facts.
-AEOI: brief chronology.
-AEOI: general ideas.
-AEOI: scheme.
-AEOI: specifics.
-Practical example: Cyprus.
-What is “substance” and where does it come from?
-Today`s substance requirements.
-Actions and measures, indicating “substance”.
-Issues to be considered during the obtainment of Cyprus tax residency certificate.
-Questions asked by tax authorities investigating into substance over form.
MCI CLT Dutch Holding Structures EN (2021.03)Martin Kraeter
The various options of the Dutch Corporate Law with regards to Holding Structures. Reflecting on:
Dutch Participation (Deelnemingsvrijstelling)
Holding Subsidiaries
Tax Treaty Network
EU Withholding Tax Exemption
Dutch Finance Company (DFC)
Dutch Cooperative (DCOOP)
Stichting & STAK
Hybrid Holding
Eversheds CREATE Workshop #1: Real estate holding structuresEversheds Sutherland
Corporate Real Estate Academy Training at Eversheds (CREATE) is a series of workshops designed to further your knowledge of indirect real estate and corporatised real estate transactions.
CREATE Workshop #1: Real Estate Holding Structures explored:
• typical structures used for holding real estate and real estate joint ventures
• why each structure is used and by whom
• trends and how the status quo is changing
Future of treaty formed holding companies and preferential Harm J. Oortwijn
Past present and future developments in holding and preferential tax regimes - what once was appropriate is now perceived inappropriate... and the perception continues to evolve!
Table overview of essential facts and requirements for setting up investor funds / hedge funds in the low tax EU jurisdiction of Malta.
* Collective Investment Schemes | Hedge Fund | Mutual Fund | AIFMD | PIFs | Alternative Investment Schemes
Automatic exchange of information (AEOI) - November 2016nztaxpolicy
Presentation delivered in November 2016 (Wellington - 4th November, Auckland - 9th November, webinar - 18th November) aimed at financial institutions and covered the practical implementation and technical issues for the Common Reporting Standard.
Ireland is an advantageous location for holding companies, due to:
- Favourable tax treatment of dividend income;
- No Withholding Tax on dividends from Irish Holding Company to EU / tax treaty countries;
- No Capital Gains Tax on disposal of shareholdings in subsidiaries;
- Favourable tax regime for R&D / intangibles;
- Tax deductions for interest on borrowings;
- Favourable Withholding Tax regime for interest and royalty payments
- & more...
Ireland is an advantageous location for holding companies, due to:
- Favourable tax treatment of dividend income;
- No Withholding Tax on dividends from Irish Holding Company to EU / tax treaty countries;
- No Capital Gains Tax on disposal of shareholdings in subsidiaries;
- Favourable tax regime for R&D / intangibles;
- Tax deductions for interest on borrowings;
- Favourable Withholding Tax regime for interest and royalty payments
- & more...
Presentation. Are you the beneficial owner of the income? And is substance adequate? How much substance is need? Cyprus as a case study. Automatic Exchange of Information. Christos Theophilou - Taxatelier Ltd, Cyprus.
Luxembourg has created a global services package with advantages for Israeli companies that want to launch their business in Europe. This presentation describes Luxembourg's legal system, history, economics and lifestyle. It was created as part of the Luxembourg/Israel Business Initiative which is led by P&TLuxembourg's TERALINK unit. The law firm of Lauer and Sartor contributed this presentation.
Luxembourg: Gateway to Develop Your Business in EuropeTERALINKnetwork
Luxembourg has created a global services package with advantages for Israeli companies that want to launch their business in Europe. This presentation gives an overview of Luxembourg's advantages, covering business, ICT infrastructure and lifestyle benefits. The Luxembourg/Israel European Business Initiative is led by P&TLuxembourg's TERALINK unit, in collaboration with KPMG and the law firm of Lauer and Sartor.
Case Study on Intrauterine Growth RestrictionAbhineet Dey
A clinically based study of a case of Intrauterine Growth Restriction (IUGR) or Foetal Growth Restriction (FGR).
Moderator:
Dr M. K. Mazumdar
Asst. Professor,
Dept. of Obstetrics and Gynaecology,
Gauhati Medical College & Hospital
Presented by:
29: Abhineet Dey
30: Devasree Kalita
31: Parishmita Sharma
33: Ankur Jain
34: Dhurjyoti Nath
35: Mousumi Mehtaz
42: Liza Hazarika
Students of 8th Semester,
Gauhati Medical College & Hospital, Guwahati, Assam
Luxembourg: Datacenter and International ConnectivityTERALINKnetwork
Luxembourg has created a global services package with advantages for Israeli companies that want to launch their business in Europe. This presentation describes Luxembourg's powerful ICT infrastructure and how Israeli companies can easily connect online with Europe's 500 million consumers. The Luxembourg/Israel European Business Initiative is led by P&TLuxembourg's TERALINK unit, with the collaboration of KPMG and the law firm of Lauer and Sartor.
The Luxembourg government took the opportunity of the transposition of the AIFMD into Luxembourg law to revamp the limited partnership regime with the aim at making it more attractive for fund managers - in particular, private equity managers.
In a nutshell, the law has revamped the existing limited partnership regime (“CLP” - common limited partnership or “SCS” - société en commandite simple) and introduced a new type of partnership (“SLP” - special limited partnership or “SCSp” - société en commandite spéciale).
The purpose of this user guide is not to provide an exhaustive accounting, legal and tax framework but rather to answer some of the typical questions private equity managers and service providers may have when setting up and administering a Luxembourg limited partnership vehicle.
Luxembourg has been at the forefront of the financial markets’ and the structured finance’s trends and evolutions. Over the years, it grew to become a hub for securitisation and structured finance transactions with one of the world’s safest business environment, notably as a result of its financial, political and social stability and innovative approach towards the financial sector. Issuers and investors in Luxembourg benefit from strong and stable regulatory and tax frameworks, in line with European Union directives and regulations.
The SIF is a regulated, operationally flexible and fiscally efficient multipurpose investment fund regime for an institutional and qualified investor base.
The investment company in risk capital (the “SICAR”) governed by the Luxembourg law of 15 June 2004 relating to the investment company in risk capital, as amended from time to time (the "2004 Law") is Luxembourg’s flagship investment vehicle for private equity/venture capital and accommodates qualified investors.
This presentation gives an introduction into Luxembourg investment funds. Comparison between regulated and unregulated funds: UCITS, SIF, SICAR, Part II, RAIF, Limited Partnerships and Securitisation Vehicles.
More information on www.nomi-lux.com
This is a short description on UCITS in Luxembourg. More details on this subject are available here https://www.startluxembourgfund.com/ucits-in-luxembourg.
20. Investment Funds In Luxembourg – at a glance LEGAL and REGULATORY Commercial Company Law of 1915 (SOPARFI) Subject to part II of 2002 Law 2002 and new 2007 Law Law of June 15, 2004 Dutch VBI Type of vehicle / regime SOPARFI FCP SICAV SIF SICAR Legal form SA, Sàrl, SCSA, SCA Fund & Management company SICAV: SA SICAF: SA,Sàrl, SCSA,SCA See FCP, See SICAF SICAV: see SICAF SA, Sàrl, SCSA,SCA SCS NV, fund for joint account, comparable EU entity, comparable Netherlands Antilles entity, comparable non-EU entity if treaty contains non-discrimination clause Investors Private Public Public Institutional, Qualified Institutional, Qualified At least two shareholders / participants Min. Capital SA: € 31,000 Sàrl: € 12,400 At least € 1,250,000 6 months delay At least € 1,250,000 6 months delay At least € 1,250,000 12 months delay At least € 1,000,000 12 months delay € 45,000 for a NV, no requirement for FJA Regulation CSSF No Standard Standard Light Light YES, unless an exemption applies. Use of Sub Funds No Yes Yes Yes No Yes Investment diversification N/A Yes Yes Just the risk spreading principle to be applied. N/A but risk capital Yes Indebtedness restrictions 15/85 (holding activity) Limited, max 50% of net assets Limited, max 50% of net assets No No No
21. Investment Vehicles In Luxembourg – at a glance TAX SOPARFI FCP SICAV SIF SICAR Dutch VBI Tax transparency NO YES NO YES / NO YES / NO YES / NO depending on legal form Corporate taxes YES NO NO NO NO / YES but can be 0 effectively NO, exempt from Dutch CIT Capital Duty 1% (Draft Budget Law - 0.5% 2009, Abolished in 2010) € 1,250 € 1,250 € 1,250 € 1,250 NO NWT 0.5% of the unitary value Exemption and reduction possible NO NO NO NO NO WHT Dividends 15% NO NO NO NO NO Interest (beware of EUSD) NO NO NO NO NO NO Liquidation NO NO NO NO NO NO Annual subscription tax NO 0.05% NAV Reduction to 0.01% and exemption possible 0.05% NAV Reduction to 0.01% and exemption possible 0.01% NAV Exemption possible NO NO DTT access Yes N/A Limited N/A / Limited NO / YES NO (if treaty access is required it can use a Dutch coop as a subsidiary of the VBI) EU Commission Questions State Aid? NO
22.
23. Recognition of Irish CCFs - Tax Transparency Major Markets Country Transparent Non Transparent Australia Yes? Austria Yes Belgium Yes Canada Yes France Yes? Germany Yes Italy No? Japan No? Norway Yes Spain No Switzerland Yes The Netherlands Yes U.K. Yes U.S. Yes