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Established in 1923
Copyright © 2013 | Wildgen, Partners in Law
Wildgen, Partners in Law, whose origins go back to
the 1920’s, is today one of the largest and best-
known law firms in Luxembourg.
Since the 1980’s, Wildgen has focused its activity on
business, corporate, tax, and financial law,
undergoing significant development together with the
upsurge in the Luxembourg financial market.
While remaining fully independent, Wildgen boasts
a wide network of foreign correspondents and
contacts, and collaborates with experts worldwide.
Wildgen is fully-committed to the success of its
clients and stresses the values of the profession in a
modern world: a sense of ethics and integrity, pro-
activity and responsiveness, a multilingual and
multicultural staff, and the utmost flexibility in meeting
our clients needs and adapting to the ever-changing
market.
Wildgen offers a wealth of experience and a strong,
long-standing track record in advising on cross
border transactions.
Over the years, Wildgen has acquired a strong client
base in Europe, C.I.S, U.S.A, Middle East, and Asia.
It represents a number of multi-national corporate
institutions, investment (mutual) funds, pension
funds, private equity funds, leading banking and
financial institutions, and insurance service providers.
Wildgen’s lawyers assist clients with regard to all
legal matters in the following practice areas:
Administrative Law, Aviation and Maritime,
Banking and Financial Law, Capital Markets,
Corporate Finance, Corporate Law, Employment
and Pensions, Insurance Law, Investment Funds,
IP/TMT, Islamic Finance, Litigation and
Arbitration, Real Estate, Securitisation, Tax,
Private Equity and Venture Capital.
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Table of Contents
NEW “PAYMENTS LEGISLATIVE PACKAGE” ADOPTED BY THE EUROPEAN
COMMISSION .................................................................................................. 4
LUXEMBOURG LAW CREATING THE NEW CATEGORY OF PROFESSIONALS OF THE
INSURANCE SECTOR ........................................................................................ 7
LUXEMBOURG AIFM LAW: IMPACTS ON THE BANKING & FINANCE AND CAPITAL
MARKET SECTORS ........................................................................................... 9
THE LUXEMBOURG DOUBLE TAX TREATIES NETWORK ..................................... 13
AMENDMENT OF THE REGULATION ON BANKS ISSUING MORTGAGE BONDS .... 15
WILDGEN‘S NEWS ......................................................................................... 16
ITECHLAW COMMITTEE NOMINATION ............................................................ 17
BREAKFAST BRIEFING ON SOCIAL ELECTIONS .................................................. 17
UPCOMING EVENTS ....................................................................................... 18
Copyright © 2013 | Wildgen, Partners in Law
New “Payments Legislative Package”
adopted by the European Commission
Michel Bulach (Partner) - Frédéric Gervais (Director) -
Luis Marques Guilherme (Senior Associate) - August 2013
On July 24th
, 2013 the European Commission published the awaited proposal for
a revised Payment Services Directive (“PSD2”)1
having for its purpose to
complete and recast the Payment Services Directive (N° 2007/64/EC, “PSD1”)
implemented in the Grand Duchy of Luxembourg by the Law of November 10th
2009 on payment services.2
The aims of the PSD1, which were the harmonisation of the legislation on payment
services throughout the European Union (and extended to the EEA area), the
implementation of new payment products (based on the SEPA products) allowing
cross-border payments in Euro as simple and secure as domestic payments, and the
improvement of the protection of the payment services users (“PS users”), are found in
the PSD2.
If approved, PSD2 will widen the scope of application of the European legal framework
related to payment services.
New players in the payment services will qualify as payment services providers
(“PSP”), namely the “third-party Payment Service Providers,” providing:
payment initiation services, i.e. services enabling the access to a payment
account, where the payer can be actively involved in the payment initiation or
the third-party PSP’s software, or where payment instruments can be used by
the payer or the payee to transmit the payer’s credentials to the PSP holding
the payment account; and,
account information services, i.e. a payment service where consolidated and
user-friendly information is provided to a PS user on one or several payment
accounts held by the PS user with one or several PSPs.
1 http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=COM:2013:0547:FIN:EN:PDF
More information available on: http://ec.europa.eu/internal_market/payments/framework
2 Mémorial A 215, 11 novembre 2009 http://www.legilux.public.lu/leg/a/archives/2009/0215/a215.pdf#page=2
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These third-party Payment Service Providers will be subject to the same regulatory
requirements and supervision as those applicable to any entity already qualifying as
PSP.
Furthermore, PSD2 will extend the application of rules related to the transparency and
obligations of information of PS users to the “one-leg transactions.” Under the PSD1,
rules governing the compulsory information and transparency of the services of
payments apply only to payments made from and in the EU (i.e. where the PSP of the
payer and of the payee are both located in the EU) and in the Euro or another member
State currency. Under the PSD2, PSPs located in the EU will have to comply with the
same transparency and information obligations each time they provide a payment
service, notwithstanding the fact that such payment could originate from or be made to
an account located outside of the EU and notwithstanding the currency (Euro, EU or
non-EU currency) of the payment.
PSD2 will further reinforce security rules for online transactions and places under the
PSPs’ responsibilities the obligation to enforce stronger consumer authentication
procedures, i.e. procedure based on the use of at least two elements categorised as
knowledge, possession, and inherence and that are independent (e.g. for the use of a
debit card: the possession of the card and the use of a PIN code).
The liability regime of the PSP will also be amended under the PSD2.
In cases of unauthorised card payments, consumers will have to bear losses up to a
maximum of 50 EUR (instead of 150 EUR currently). Moreover, the PSD2 will grant the
consumer an unconditional right to a refund of any disputed payment transactions, in
cases of card payment or domiciliation (this refund right will be aligned with the existing
SEPA SDD standard), except where the payee has already fulfilled the contractual
obligations and the services have already been received or the goods have already
been consumed by the payer.
The proposal of the Commission to recast the payment services regulation is
completed by a proposal of Regulation on Multilateral Interchange Fees (MIFs) (the
“Regulation”), having for its purpose to regulate at the European level the interchange
fees applicable on debit and credit card transactions and card-based payment
transactions undertaken through “banking” cards. Commercial cards or three party
scheme cards will be excluded from the regulation.
Copyright © 2013 | Wildgen, Partners in Law
Maximum levels of interchange fees will be imposed for cross-border transactions
during a transition period of two years following the publication of the Regulation. It is
therefore proposed that, after the transitional phase, the same maximum fees that
apply to cross-border acquired transactions will also apply to domestic transactions. All
(cross-border and domestic) 'consumer' debit card transactions will have a maximum
interchange fee of 0.20% and all (cross-border and domestic) ‘consumer’ credit card
transactions will have a maximum interchange fee of 0.30%.
The Regulation further provides for business rules that will be applicable to all
categories of card transactions, notably:
transparency rules (PSPs will have to provide at least monthly statements to
their clients acting as merchants, disclosing the fees paid by the merchant
concerning each category of card);
no discrimination between card users as regards the issuing bank or the
provenance of the card holder (however, without prejudice to the limitation of
the “Honor All Cards Rule” set forth by the regulation);
prohibition of any regulation preventing or limiting merchants from steering
customers to more efficient payments instruments ('no steering rules'); and,
merchants shall be entitled to disclose to their customers the fees they pay to
their PSP.
At this time, the PSD2 Directive and the MIFs Regulation proposals have been
released as provisional versions, but already allow professionals, users and
practitioners to consider and start anticipating the new legal framework to come.
To be continued…
The article is available on our website
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Luxembourg Law creating the new category of
Professionals of the Insurance Sector
Michel Bulach (Partner) - August 2013
The Luxembourg legal framework of the insurance sector is about to experience
significant changes in the coming months. The implementation of Solvency II
directive is still a legislative work in progress with two legs, consisting in a draft
bill that will restate in full the existing law of 1991 on the insurance sector and a
second draft bill that will amend both the law of 1997 on insurance contracts and
the law of 1994 on annual accounts of insurance and reinsurance companies.
The Luxembourg legislator has however decided to move forward ahead of the
forthcoming Solvency II legal instruments with the vote and publication of the law dated
12 July 2013 that amends the law of 1991 by creating a new category of Professionals
of the Insurance Sector and restating provisions governing insurance and reinsurance
intermediaries as well as authorised managers of companies active in the insurance
sector.
Although the concept of Professional of the Insurance Sector, inspired from the
longstanding and ever-evolving group of Professionals of the Financial Sector, is brand
new to the world of Luxembourg insurance, its scope partly covers and supplements
the provisions that previously applied to certain professionals such as the companies
providing management services to reinsurance undertakings or to pension funds.
The new law however goes further by authorising and regulating new professions such
as management companies for insurance captives, actuarial service providers or
governance service providers, which are notably expected to play a role in helping
small and medium-size insurance and reinsurance companies to adapt to future
Solvency II organisational requirements by widening their outsourcing possibilities.
Other specialised professionals like run-off management companies and claim
handlers will usefully complete the Luxembourg offer of services to the insurance and
reinsurance industry.
From an international perspective, foreign professionals intending to set-up a branch in
Luxembourg in order to provide services that fall under the scope of the new category
shall apply for a license in Luxembourg under the same conditions as Luxembourg
professionals.
Copyright © 2013 | Wildgen, Partners in Law
The complete list of Professionals of the Insurance Sector as set forth under the law of
12 July 2013 is the following:
management companies for insurance captives
management companies for insurance undertakings in run-off
management companies for reinsurance undertakings
management companies for pension funds
authorised provider of actuarial services
insurance portfolio management companies
authorised provider of services relating to the governance of insurance and
reinsurance undertakings
claim handlers / loss adjusters
It has to be noted that insurance and reinsurance intermediaries (brokers and agents)
are not caught under the category of Professionals of the Insurance Sector due to the
existence of a specific set of European legal instruments applicable to them.
The law of 12 July 2013 nevertheless restates and supplements the rules previously
applicable to brokers in a way that is quite similar to the provisions now governing the
professionals of the insurance sector in terms of financial assets, professional liability
insurance, audit reporting and supervision. By way of example the law provides for the
application of the same requirements of minimum financial assets to individual brokers
(net assets of EUR 25.000.- upon authorisation to be brought to EUR 50.000.- within 5
years) and to brokerage firms (paid-in capital of EUR 50.000.- upon authorisation to be
brought to EUR 125.000.- within 5 years) as those applicable to Professionals of the
Insurance Sector.
With this new legislation Luxembourg has implemented the first piece of a process
aiming at maintaining a harmonised level playing field for the Luxembourg insurance
industry while preserving its specificities. Although (or because) they imply a higher
level of regulation and an adaptation to new standards, it is expected that those legal
instruments will have positive results on the market and be an asset to industry players
in developing the new opportunities that may follow from them.
The article is available on our website
Copyright © 2013 | Wildgen, Partners in Law
Luxembourg AIFM Law: Impacts on the Banking
& Finance and Capital Market sectors
Mevlüde-Aysun Tokbag (Partner) - Giuseppe Cafiero (Associate) -
Katarina Gerard (Junior Associate) - August 2013
Potential impacts of the new Luxembourg law on alternative investment fund
managers adopted on 10 July 2013, effective since 15 July 20133
, and
implementing the Directive 2011/61/EU of the European Parliament and of the
Council of 27 May 2011 regarding alternative investment fund managers (the
“AIFM Law”) on the Luxembourg Banking & Finance as well as the Capital
Market sectors:
1) Private Placements
The AIFM Law impacts, inter alia, a so-called private placement in Luxembourg. A
private placement consists in marketing of securities to a relatively small number of
selected investors as a way of raising capital and, as such, does not principally fall
within the scope of the Luxembourg law of 10 July 2005 on prospectuses for securities,
as amended. In this respect, the Luxembourg supervisory authority of the financial
sector (Commission de Surveillance du Sector Financier - the “CSSF”) confirms in its
recently published Frequently Asked Questions (dated 19 July 20134) that both EU and
non-EU alternative investment fund managers (the “AIFM”) may continue to market
both their EU and non-EU alternative investment funds (the “AIFs”) in Luxembourg
under the existing Luxembourg private placement rules while remaining unaffected by
the provisions of the AIFM Law until 22 July 2014 (being, however, uncertain as to
whether this applies only to existing placements and/or also to new placements of
existing AIFs).
Thereafter, the EU AIFMs will have to comply with the provisions of the AIFM Law,
being an authorisation by or registration with the CSSF as an AIFM (if other criteria are
met and/or relevant exemptions are not applicable). In addition, further to ESMA’s
3 Mémorial A 119 of 15 July 2013, http://www.legilux.public.lu/leg/a/archives/2013/0119/a119.pdf
4 http://www.cssf.lu/fileadmin/files/AIFM/FAQ_AIFMD.pdf
11 | P a g e
approval of centrally-negotiated co-operation arrangements with 34 non-EU securities
regulators, the CSSF announced via press release on 31 May 2013 that it has signed a
memorandum of understanding with each of these non-EU authorities such as, inter
alia, Hong Kong, USA, Singapore, and Switzerland. As a consequence, those non-EU
AIFMs may continue their marketing activities for EU and non-EU based AIFs in
Luxembourg under the private placement regime until July 2015 (but after 22 July 2014
subject to the compliance of some requirements of the AIFM Law) and potentially with
a passport thereafter.
2) New PSF
By amending the Luxembourg law of 5 April 1993 regarding the financial sector as
amended (the “PSF Law”) the AIFM Law (laying down the mandatory appointment of
an independent depositary by the AIFs) provides for a new category of professional in
the financial sector (the “New PSF”), which will enable non-credit institutions to act as a
depository for AIFs (new article 26-1); being the status of the “professional
depositary of assets other than financial instruments.”
This New PSF is allowed to act as depositary for Luxembourg SIFs, SICARs, and other
AIFs governed by the AIFM Law which (i) have a lock-up period of five years as from
the date of the initial investments, and (ii) in accordance with their investment policy, do
not invest in assets which need to be held in custody or in non-listed entities or
companies (e.g. investment capital funds or companies, venture capital funds or
companies, real estate funds or companies) in order to eventually take their control.
Depositaries of AIFs can also delegate to this New PSF the safekeeping of non-liquid
assets or assets other than financial instruments. Only corporate entities having a
minimum subscribed and paid-up share capital of EUR 500,000 can be authorised to
act as professional depositary of assets other than financial instruments. This New
PSF status can be combined with other PSF status, for example fund administrator or
transfer agent, as long as the administrative and the depositary functions within the
same entity are duly segregated in order to avoid any potential conflicts of interest.
The AIFM Law also provides for the abolition of the PSF status of “managers of non-
coordinated UCIs” effective as of 22 July 2014. This status is currently governed by
article 28-8 of the PSF Law.
Copyright © 2013 | Wildgen, Partners in Law
The activity of this PSF is limited to the management of foreign non-UCITS funds. As
the main part of such funds is qualified as AIFs under the AIFM Law, their
management shall now only be entrusted to an AIFM duly authorised under the AIFM
Law. As a consequence thereof and in order to continue their activity, managers of
non-coordinated UCIs shall comply with the provisions of the AIFM Law and, in
particular, shall apply for an authorisation to act as an AIFM prior to 22 July 2014. After
this deadline, any existing manager of non-coordinated UCIs who has not been
authorised as an AIFM will no longer be authorised to manage non-coordinated UCIs.
3) Securitisation
The AIFM Law generally does not apply to “securitisation special purpose entities”;
however, as it refers to entities whose sole purpose is to carry on a securitisation within
the meaning of article 1 (2) of Regulation (EC) 24/2009 of the European Central Bank
of 19 December 2008 on statistical reporting. Compared to the Luxembourg law of 22
March 2004 on securitisation, as amended (the “Securitisation Law”), this European
Central Bank regulation provides a much more detailed definition of securitisation and
therefore it is not broad enough to cover the entire securitisation and structured finance
business in Luxembourg.
The Securitisation Law indeed provides a very broad definition of securitisation, which
allows for almost any asset producing a regular flow of income or any risk to be
securitised and consequently in light of this broad concept of securitisation,
Luxembourg has become an attractive jurisdiction for structured finance and
securitisation transactions over the last years. However, based on this broad concept
of securitisation under the AIFM Law, certain vehicles may not necessarily, or at least
not automatically, fall within the AIFM Law exemption on securitisation and thus there
is a risk that such vehicles may indeed be classified as an AIF.
The article is available on our website
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The Luxembourg Double Tax Treaties Network
Tax Practice Group & Knowledge Management Department - September 2013
Latest updates
13 September 2013. Protocol on exchange of information upon request with Poland is
in force as of 25 July 2013 and with Russia as of 30 July 2013. New tax treaty with
Macedonia is in force as 23 July 2013, with Tajikistan as of 27 July 2013 and with
Seychelles as of 19 August 2013 (Mémorial A 168, 13 September 2013). The three
new tax treaties include the international standard of exchange of information upon
request
30 July 2013. Luxembourg and Mongolia to begin new tax treaty negotiations to
facilitate better access to investment services.
26 July 2013. Protocol on exchange of information upon request with Belgium is in
force as of 25 June 2013 and with Switzerland as of 11 July 2013 (Mémorial A 134, 26
July 2013)
25 July 2013. Protocols on exchange of information upon request with Romania and
Malta are in force as of 11 July 2013 (Mémorial A 132, 25 July 2013)
04 July 2013. Law of 14 June 2013 implementing new tax treaties with Germany,
Kazakhstan (protocol included), Laos (Lao People's Democratic Republic), Macedonia,
Seychelles, Sri Lanka and Tajikistan and protocols to existing tax treaties with Canada,
South Korea, Italy, Malta, Poland, Romania, Russia and Switzerland was published in
the Official Journal (Mémorial A 144, 04 July 2013). Entry into force dates will be
precised in forthcoming publications.
20 June 2013. A protocol with Slovenia was signed. This protocol will include the
international standard of exchange of information upon request.
10 May 2013. A new tax treaty with Guernsey was signed. This new treaty will include
the international standard of exchange of information upon request.
07 May 2013. On the occasion of the Euromoney Conference taking place in Saudi
Arabia, Luc Frieden, Luxembourg Minister of Finance, signed a new tax treaty with the
Saudi Minister of Finance Dr Ibrahim Al-Assaf.
Copyright © 2013 | Wildgen, Partners in Law
17 April 2013. A new tax treaty with Jersey was signed. This new treaty will include the
international standard of exchange of information upon request.
08 April 2013. A new tax treaty with Isle of Man was signed. This new treaty will
include the international standard of exchange of information upon request.
15 March 2013. A new treaty with Singapore was initialed. This new treaty will replace
the initial 1993 treaty when it will be applicable.
07 March 2013. Draft law 6552 implementing new tax treaty with Taïwan submitted to
the Luxembourg Parliament.
07 March 2013. The Finance Ministers of Luxembourg and the Czech Republic signed
on Tuesday 05 March an agreement on preventing double taxation which replaces the
agreement of 1991. This new treaty will include the international standard of exchange
of information upon request.
Situated at the crossroad of Europe, the Grand-Duchy of Luxembourg is based
on a dynamic and open economy which actively promotes the development of
cross border trade and investments. Its major role in matter of international trade
in the sectors of banking and finance, investment funds and holding companies
has for a consequence that a strong network of double tax treaties has been
developed over the years. To that end, Luxembourg has entered into 64
comprehensive double tax treaties based on the OECD model tax convention on
income and capital in order to mitigate the risks of double taxation for
businesses.
The Grand Duchy treaty partners are amongst the most industrialised countries with
inter alia all of the states in the European Union but Cyprus, the United States, Japan,
Brazil, China, Mexico, Hong Kong and Russia, Canada. Luxembourg tax treaties as
most bilateral agreements are designed and balanced to address a specific economic
context. Given their very nature, tax treaties are constantly negotiated and updated to
the latest international standards.
Another perspective to the steady expansion of Luxembourg tax treaties must be
added. Luxembourg endorsed on 13 March 2009 the international standard of
exchange of information upon request embodied in article 26-5 of the OECD model tax
convention. As a result, 31 treaties containing the said standard were concluded at the
moment.
The article and list are available on our website
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Amendment of the regulation on banks issuing
mortgage bonds
Frédéric Gervais (Director) - July 2013
The Law dated 27 June 2013 relating to the banks issuing mortgage bonds and
amending the Law of 5 April 1993 on the financial sector, has been published in
the Luxembourg Official Journal on 1st July 20135.
Mortgage banks are credit institutions having as their main object the granting of loans
secured by rights on immoveable property, bonds or similar debt instruments,
commitments from public entities (as specified by the Law of 5 April 1993), and the
issuing on that basis of debt instruments secured by those rights or charges, such
instruments being known as mortgage bonds.
The regulation on mortgage banks as amended by the Law dated 27 June 2013 is
improved with regard to the liquidation / “sursis de paiement” process applicable to
mortgage banks, in a view to protect the interests of holders of mortgage bonds, and
by the insertion of a new type of mortgage bonds, namely mutual mortgage bonds,
which are:
loans granted to credit institutions (participating in a deposit-guarantee
scheme) established in EU, EEE, or OCDE countries and the issue of
mortgage bonds guaranteed by the receivables resulting from the loans; or,
loans granted by a mortgage bank and guaranteed by bonds issued by credit
institutions, the mortgage bank issuing mortgage bonds guaranteed by the
receivables resulting from the loans.
This Law has entered into force on 4 July 2013.
Should you need assistance or more information about this requirement, please do not
hesitate to contact Michel Bulach or Mevlüde-Aysun Tokbag, Banking and Finance
Partners.
The article is available on our website
5 Mémorial A 111 of 01 July 2013 http://www.legilux.public.lu/leg/a/archives/2013/0111/a111.pdf
Copyright © 2013 | Wildgen, Partners in Law
Wildgen‘s News
WILDGEN’S NEWS
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ITechLaw Committee Nomination
We are delighted to announce that Emmanuelle
Ragot, Head of IP/TMT, has been nominated
and appointed to serve as Vice-Chair for the
ITechLaw's Data Protection Substantive Law
Committee for the coming year.
Committee leaders are key members of
ITechLaw’s leadership team and this nomination
confirms her position as Luxembourg key expert for
data protection issues.
ITechLaw has been serving the technology law
community worldwide since 1971 and is one of the most
widely established and largest associations of its kind. It
has a global membership base representing six
continents and spanning more than 60 countries. Its
members and officials reflect a broad spectrum of
expertise in the technology law field.
Breakfast Briefing on Social Elections
On 13th
November 2013, social elections
will be held in Luxembourg and employees
will have the opportunity to elect members
of their company’s staff delegation and of
the Chambre des salariés.
Considering the importance of these
elections, Jackye Elombo, Partner, and
Jerome Commodi, Associate, both
specialising in Employment Law at Wildgen, will lead a breakfast briefing
presentation on social elections on 30th
September at 8.30a.m. at Wildgen’s
premises. On this occasion, they will detail the practical aspects and issues related to
this procedure in order to avoid any problems arising from these elections.
Contact / Registration:
[email protected] +352 40 49 60 205
Copyright © 2013 | Wildgen, Partners in Law
Upcoming Events
2 OCTOBER 2013 - 4 OCTOBER 2013
ITECHLAW 2013 EUROPEAN CONFERENCE
The ITechLaw 2013 European Conference, organised in Amsterdam from the 2nd to
the 4th October 2013, brings together the world’s leading technology lawyers who will
discuss on topical mobile payment systems, outsourcing, cloud, data protection,
intellectual property and regulatory developments issues.
As Head of IP/TMT at Wildgen, Partners in Law, Emmanuelle Ragot will
participate in this unique event as a speaker and will draw up an overview of the
different factors making Luxembourg a strategic location for technologies
business and IP rights.
6 OCTOBER 2013 - 11 OCTOBER 2013
INTERNATIONAL BAR ASSOCIATION ANNUAL CONFERENCE
Pierre Metzler and Michel Bulach, both Partners at Wildgen, attend the next IBA
Annual Conference organised from 6th to 11th October 2013 in Boston. On this
occasion, Wildgen is delighted to organise/sponsor two events:
Meet International Friends in Boston
Organised by Wildgen to bring together lawyers from European & US
jurisdictions, this breakfast will be held on 8th October 2013 at the Four
Seasons Hotel (Boston).
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IBA Committee on Banking Law and Securities Law
Wildgen sponsors and takes part in the IBA Committee on Banking Law and
Securities Law to be held on 8th October 2013 at 12.45. This joint lunch is
arranged by IBA Committees to enable their members and other delegates
interested in the committees activities to meet informally in a relaxed
atmosphere, and are a key element of the more practice-specific networking
available at the IBA Annual Conference.
Feel free to contact us at [email protected] should you need more information
about Pierre and Michel's participation in those events.
Pierre and Michel are looking forward to meeting you there.
Venue (Meet International Friends in Boston):
Four Seasons Hotel
Conference Room Gilbert Stuart
200 Boylston Street
MA 02116 Boston
Venue (IBA Committee on Banking Law and Securities Law):
Grill 23
161 Berkeley Street
MA 02116 Boston
Copyright © 2013 | Wildgen, Partners in Law
69, boulevard de la Pétrusse
L-2320 Luxembourg
Tel: +352 40 49 60 1
Fax: +352 40 44 09
www.wildgen.lu
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comprehensive statement of the law. Therefore, WILDGEN can not accept any liability for any errors, omissions or opinions contained herein and for the implementation of the principles set out without its active involvement.
