Presentation Financial Seminar Riyadh Final

Luxembourg, a global financial centre for asset and wealth management services

Riyadh, May 17, 2010

Luxembourg, an international hub for

financial services

Fernand GrulmsCEO, Luxembourg for [email protected]+352 27 20 21-1

3

The Luxembourg financial centre

… at a glance :

Europe’s number one investment fund centre (number 2 worldwide behind the US)

N 1 wealth management centre in the Eurozone

Europe’s leading domicile for captive reinsurance companies

3

Luxembourg: financial centre,but also...

4

5

International financial centresInvestments managed in international centres, $bn, end-2007

Source: Bank for International Settlements, International Monetary Fund

3’615

1’1281’2551’317

2’451

2’954

5

International competitiveness

indicatorsSource Ranking

LuxembourgAnalysed

locations/countries

Growth Environment Score (GES)

Goldman Sachs, 2005 1 170

Global Competitiveness Index IMD Lausanne, 2008 5 55

Growth Competitiveness Index (GCI)

World Economic Forum, 2009 21 133

Index of Economic Freedom

Heritage Foundation & Wall Street Journal, 2009

15 183

Regional European Competitiveness Index

Robert Huggins associates, 2006 6 118

Competitive environment

6

Luxembourg financial intermediaries

Banks150

Investment funds> 3,516 (12’513 units)

InsuranceLife : 53

P&C : 40

Reinsurance : 261

Professional intermediaries(asset managers,brokers, transfer

agents…)

290

Source: CSSF, CAA

7

What do all thesefinancial intermediaries do

in Luxembourg ?

8

- banking- insurance- reinsurance- securities- investment funds

The principle of the european passport

- hedge funds- private equity- real estate

No EU passport yet

9

The Luxembourg financial centre

Employment

Direct employment44,000

Banks, other financialintermediaries, insurance

48,000

Law firms Audit, Tax

Other ICT

30,000

Source: CODEPLAFI, 2007

45’000 are university graduates

10

Luxembourg : well regulated

Minister of Finance

Commission for the supervision of the

financial sector

InsuranceCommission

Luxembourg Central Bank

Macro supervisionSystemic risk

LiquidityPayment systems

BanksFinancial intermediaries

Securities Markets

Investment fundsPension fundsOther vehicles

Life insuranceP & C insurance

ReinsuranceCaptives

11

Luxembourg: highly international

… in terms of origin of banks

Figures as at March 31, 2010, Source: CSSF

Others

12

Luxembourg : highly international

… in terms of origin of fund promoters

Market shares in terms of assets under management Figures as at December 31, 2009, Source :CSSF

21,1

19,0

15,911,9

7,7

8,56,8

1,6

3,8

1,62,1 Others

13


… in terms of origin of captive reinsurers

Country of origin ofthe parent company

Sector of the parentcompany’s activity

67

48

131017

19

36

1620

15Others

Source: CAA Annual Report 2008

21

77

15

30

41

15

42 14 6

Distribution

Industry

Telecomm.

TransportOther

FoodProcess

Insurance

Banking

Chemistry

14


… in terms of clients

The example of private banking

B, F, D

Latin AmericaUSAAsia

Middle East

Luxembourg

12%

16%

26% 46%

Other EUSource: ABBL

15


Source: CAA Annual Report 2008

21,8%

17,2%

17,3%5,2%

10,1%

11,3%

6,5%8,4%

Other EEAcountries

2,6%Other

countries

… in terms of clients

The example of life insurance

16

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… in terms of population and work force

More than 40% of the Luxembourg population are non Luxembourgers

145,000 commuters from Germany, Belgium and France are working in Luxembourg

Most staff members speak 2 or 3 foreign languages

3

4

1

6

7

8

109

12

11

14

13

17

16

18

19

20

2223

2425

26

27

28

29

30

31

32

33

34

35

36

37

38

39

40

42

43

44

45

46

4849

50

5152

4753

60

2

5868

59

56

55

1554

62

63

65

57

70

71

75

521

72

Double tax treaties in force

Double tax treaties pending

41

736167

746469

01. Austria 02. Azerbaijan 03. Belgium 05. Bulgaria 08. Czech Rep. 09. Denmark 10. Estonia 11. Finland 12. France 13. Germany 14. Greece 16. Hungary 17. Iceland 19. Ireland

21. Italy 24. Latvia 25. Lithuania 27. Malta 32. Netherlands 33. Norway 34. Poland35. Portugal 36. Romania 37. Russia 38. San Marino 40. Slovakia 41. Slovenia 43. Spain 44. Sweden 45. Switzerland 49. Turkey 50.United Kingdom 52. Uzbekistan 55. Georgia 57. Moldavia 59. Cyprus 61. Albania 62. Kazakhstan 64. Kyrgyzstan 66. Liechtenstein 67. Macedonia 74. Armenia69. Monaco 72. Serbia 75. Ukraine

04. Brazil 06. Canada29. Mexico 47. Trinidad & Tobago51. United States60. Argentina 68. Barbados

20. Israel 28. Mauritius 31. Morocco 56. U.A.E.42. South Africa 48. Tunisia 54. India 58. Bahrain 63. Kuwait 65. Lebanon 70. Pakistan 71. Qatar 73. Syria

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We are connected to the world: tax treaty network

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Ongoing diversification

2005

Venture Capital

Microfinance

Fund adminstration

Securitisation vehicles

Real estate investment vehicles

Intellectual property

SIF

Covered bonds

SPF

2010

Pension funds

Philanthropy

Pension pooling vehicles

19

20

Luxembourg : key success factors

Complies with all international rules (not offshore)

Expertise of more than 40 years in international

financial transactions

Stable political, legal & social environment

=> AAA country

Strong support from Government for financial

services

Pierre Oberlé, Business Development OfficerALFI – Association of the Luxembourg Fund Industry

Bishr Shiblaq, Head of Representative Office in DubaiArendt & Medernach

Pierre Weimerskirch, PartnerErnst & Young

Marc Theisen, LawyerTheisen Law

The Luxembourg Investment Fund Sector

The Luxembourg investment fund sector… at a glance :

3516 investment funds

12 513 fund units

1980.54 billion euros in assets under management

22

Figures as at February 28, 2010; Source: CSSF

The Luxembourg investment fund sector

0

5

10

15

20

25

US DE CH GB IT BE FR NL SE LU Others

%in terms of net assets

Market shares (%) of promoters of Luxembourg domiciled funds by country of origin in terms of assets under management

2323

Figures as at December 31, 2009; Source: CSSF

Peru 93%

Chile 78%

Singapore 67%

Japan 76%

Hong Kong 72%

South Korea 100%Switzerland 73%

France 73%

Germany 73%Sweden 80%

Italy 78%Bahrain 77% Taiwan 72%

Luxembourg market share of foreignfunds registered for sale

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Luxembourg: center for global distribution

76.2

12.9

2.5

2.1

1.3

0 10 20 30 40 50 60 70 80

Luxembourg (LU)

Ireland (IE)

United Kingdom(UK)

France (FR)

Belgium (BE)76.2 % of all UCITS registered

in at least 3 countries (including home state) are Luxembourg funds

25

Sources: Lipper Hindsight, 31.12.2007, PWC Global Fund Distribution 2008

26

The Luxembourg investment fund sectorPrincipal markets for distribution of Luxembourg investment funds

(in terms of the number of registrations)

0

500

1000

1500

2000

2500

3000

3500

4000

4500

Ger

man

y

Aus

tria

Switz

erla

nd

Fran

ce

Spai

n

Net

herla

nds

Italy

Uni

ted

Kin

gdom

Swed

en

Finl

and

Bel

gium

Sing

apor

e

Port

ugal

Nor

way

Chi

le

Hon

g K

ong

Den

mar

k

Cze

ch R

epub

lic

DE AT CH FR ES NL IT GB SE FI BE SG PT NO CL HK DK CZ

Americas

Asia Pacific

Europe

26

Sources: Lipper Hindsight, 31.12.2007, PWC Global Fund Distribution 2008

Bishr Shiblaq, Head of Representative Office in DubaiArendt & Medernach

Luxembourg investment funds:particular focus on UCITS

Key criteria UCITS Non-UCITS SIF SICAR

Investment restrictions

(eligible assets)Restricted Flexible Flexible Moderate

Risk diversification High Medium Low None

Ease of public distribution High Medium Low Low

Supervisory framework

Targeted to retail investor

protection

Targeted to retail investor

protection More flexible More flexible

Time to establish Low – Medium Low-Medium Very low Low

Target investors All All Institutional / HNWI

Institutional /HNWI

The Luxembourg investment fund sector

Main distinctions between UCITS and Non-UCITS

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Source: ALFI

Eligible asset classes:□ Transferable securities□ Money market instruments□ Shares and units of UCITS and other eligible funds□ Cash□ Derivatives

• Exposure to non eligible asset classes (real estate, commodities, hedge funds) through:

□ Structured financial instruments□ Derivatives □ Closed-ended funds □ Open-ended funds

Trend towards convergence between sophisticated UCITS and alternative investment strategies:

□ Short positions through use of derivatives

Undertakings for Collective Investment in Transferable Securities (UCITS)(Part I of the law dated December 20, 2002)

29

Distribution aspects:Retail and institutional investors Single “passport” within EU and recognition beyond (EEA, Middle East, Asia, Americas)

Other features: Risk management and risk monitoringSubstance requirementsRole, scope and development of Luxembourg fund management companies (173 UCITS III management companies established in Luxembourg as at 3 February 2010)

Service providers:Central AdministrationCustodian BankAuditorTransfer AgentOther service providers


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• Approval process of UCITS:□ Filing of UCITS documentation with the CSSF:

• Prospectus / Offering Circular• Core documents (Articles of Incorporation / Management Regulations)• Description of promoter and resumes of managers / directors of the

structure□ Approval by the CSSF□ Inception of the UCITS□ Notification under the EU passport for EU countries

Filing with CSSFApproval and Notification

Start of public offer in Luxembourg

2 months notification period

Start of public offer in other EU countriesNo max. review period


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Source: CSSF

UCITS71,6%

SIF14,2%

UCI14,2%

Luxembourg Islamic UCITS

- UCITS investing in Sharia-compliant investments- Sharia Board (investment screening process)- Cleansing of dividends/revenues

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88% of the Funds are launched as investment companies (SICAV) and 12% as mutual funds (FCP).

UCITS IV

Current main development at EU level

33

Pierre Weimerskirch, PartnerErnst & Young

Luxembourg –Centre of Choice for Alternative Funds

Luxembourg – attractive location for alternative investment funds

Long established financial center of first class reputation

A world renowned “Quality Brand”

Legal structures catering for all segments of the alternative

investment funds industry

Fastest growing alternative investment fund sector in the world

Deep levels of expertise in all aspects of fund creation,

administration and distribution

A highly qualified multi-lingual workforce

Highly respected regulator, and efficient supervision

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Fund regimes for every taste

Level of regulation

Structuring flexibility

UCITS

SIF

- All Asset Classes - Restricted to well informed / sophisticated investors

- Lower level of regulation

- All Asset Classes- Public distribution without EU passport

- High level of regulation

- Restricted Asset Classes- Public distribution with EUpassport

- Very High level of regulation

SICAR

- Private Equity only- Restricted to well informed / sophisticated investors

- Lower level of regulation

SV

UCI

Part II

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Luxembourg – European hub for private equity and venture capital funds

Leading European center for regulated PE/VC fundsMore than 300 PE/VC fundsAUM in excess of $US 40 billionLeading PE/VC service providers present in LuxembourgLeading global PE houses operating in Luxembourg

< $US 40 billion AUM

< 300 PE/VC Funds

Major Payers• 3i• Apax Partners• CVC• Fortress• Goldman Sachs• Investcorp• JP Morgan• KKR• Permira• […]

37

Leading European center for regulated property fundsMore than 130 property fundsAUM in excess of $US 30 billionLeading property fund service providers present in LuxembourgLeading global “property” (fund) mangers operating in Luxembourg

Luxembourg – European hub for international property funds


< 130Property Funds

Major Payers• Aberdeen• Aviva• Black Rock• Deutsche Bank• Heitmann• Hines• ING• JP Morgan• Morgan Stanley• Pramerica• […]

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Leading European center for regulated hedge funds & FoHF More than700 hedge funds and FoHFAUM in excess of $US 128 billion Leading hedge fund service providers present in LuxembourgLeading global hedge fund managers operating in Luxembourg

Luxembourg – European hub for hedge funds & funds of hedged funds (“FoHF”)

< 700Hedged Funds & FoHF


Major Payers• Aberdeen Asset Managers• Black Rock• Crédit Risk• Deutsche Bank• Goldman Sachs• JP Morgan• Lyxor• Morgan Stanley• UBS• […]

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Redomiciliation is in the air...Luxembourg is in many cases the target country

©

Re-domiciliation of funds (incl. UCITS) from end 2007 to end 2009.

Luxembourg, 31%

Hong Kong, 17%

Cayman Islands, 11%

Guernsey, 8%

Ireland, 6%

Jersey, 6%

UK, 6%

BVI, 3%

Channel Islands, 3%

France, 3%Malaysia, 3%

Mauritius, 3%Delaware, 3%

Countries of origin Target countries

Source : Lipper & The Cayman Islands Gazette based on a sample of 36 OPC

40

Good reasons to re-domicile to Luxembourg

Access to worldwide distributionReputationAttractive tax regimePresence of global asset managersExpertise and know-howCommitment to excellence and reliabilityStable jurisdiction, predictable planning and long-term investment decisions

Renowned “Quality Brand”

Access to Worldwide Distribution

41

Alternative investment trends: Thematic funds

Clean (green) technologies/SRI fundsPassion funds/Emotional assets funds“Distressed” (property) assets fundsMicrofinance fundsNanotechnology fundsGreen PE/VC fundsGreen infrastructure (wind, solar, water) fundsSharia compliant PE/RE fundsEtc.

42

Luxembourg : a Hub for Shariah Compliant Investment Funds

Marc Theisen, LawyerTheisen Law

Luxembourg: an history of innovation in theEuropean Islamic finance market

□ 1978 First islamic finance institution established in a westerncountry (Islamic Banking system)

□ 1982 First life insurance company (Takafol SA, actuallySolidarity Takafol SA)

□ 1983 First Shariah compliant insurance company in Europe(Bahraini Solidarity Group)

□ 2002 First European stock exchange to enter sukuk market(Malaysia Global Sukuk)

□ 2009 Platform “Al Mi’yar” (Shariah compliant Securities)

A first mover in Europe

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Full support of all authorities and institutions

April 2008: Luxemburg Financial Center(Luxembourg for Finance; ALFI)

July 2009: Governmental support:Declaration of the Government

November 2009: Central Bank of Luxemburg(IFSB member)

45

Structuring Islamic Finance investment

Luxembourg is perfectly equipped to address the dynamic needs of Islamic finance investments in and through Europe

□ Regulated Investment Vehicles : UCIT part I and part II

□ Semi regulated Investment vehicles: SIF / SICAR

□ Unregulated holding companies: SOPARFI / SPF

□ The Luxemburg securitization vehicle (SV)

46

Luxembourg and Islamic Finance

38 Sharia compliant funds

16 Sukuk with a combined value of USD 7.3 billion listed at the Lux stock exchange (Bourse de Luxembourg)

4th domicile for Shari’ah compliant funds in the world with 7% of them, following Malaysia (23%), Saudi Arabia (19%) and Kuwait

Luxembourg moves to the Golf (fiduciaries, law firms, serviceproviders, A.L.F.I.)

47

How Luxembourg can help you developing your business

EXPERTISEN 1 fund international servicing centre in Europe and the 2nd worldwide - 152 Banks

QUALITYHigh quality regulated framework for UCITS and non UCITS funds

LEADERSHIPWorldwide leadership in cross border distribution of financial products

FLEXIBILITYFlexible and tax efficient structures

DEVELOPMENTCommitted to develop Shariah compliant solutions. Stable and predictable environement.

48

Taxation of shariah products

49

Tax circular from the Director of Contribution 12thJanuary 2010

Circular covers whole range of Islamic Financeproducts: Specific rules: Murabaha and Sukuk

Liberal approach to Islamic transactions

Pragmatic and open minded position

49

Islamic products in Luxembourg

Islamic products to be set up within the existing legal and tax framework of Luxembourg

50

Mudaraba Ijara MurabahaWakala Sukuk

50

Conclusion

51

Strenghts

VehiclesFull Range

Futur PE, Sukuk

MarketMarket to Market,

Crossborder

TargetMiddle Eastern investors,

Institutional investors, HNWI, West European Muslim

Population (15M)

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Atman Haloui, Head of MENA MarketsBanque de LuxembourgAmran Ansar, Tax Adviser and Consultant in Islamic FinanceKPMG Tax

Luxembourg: The Leading European place for wealth management solutions

Agenda

INTRODUCTION

1. Shari’ah compliant investment vehicles available in Luxembourg

2. Selection of the right investment vehicle

3. Benefit from Luxembourg as a platform

3.1 Investing in Europe through a SIF vehicle

3.2 Structuring acquisition of European companies / real estate through Luxembourg

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INTRODUCTION

54

ALL ROADS LEADS TO LUXEMBOURG

Highly attractive country

Unprecedented political and economic stabilityTradition of a Private Banking spiritInternational environment, multi-lingual, multi-culturalWealth managers are highly mobileFounding member of the European UnionHub for European activities: EU PassportInvestor protection – MiFIDProtection of private sphere, financial privacyCompetitive fiscal framework, within the OECD/G20 standardsDeposit guarantee scheme – banking, insurance

55


Luxembourg has to be on the screen radar of:

Family members in Saudi Arabia and around the worldInvestments outside of Saudi Arabia:real estate, private equity, life style…Entrepreneurs wanting to internationalize their businessExpatriatesFamily offices or asset managers seeking a cross border platform complementary to their local providersPhilanthropy, Socially Responsible Investments

56


Luxembourg compared to other financial centers

Complementary offering to domestic solutions, other PB centersIdeal for complex, wealthy, international clients and familiesFull range of private banking products and servicesComplemented by comprehensive range of estate and tax planning solutionCompetitive fee structureLarge number of specialist service providers, working closely with banksIdeal platform for investing or operating in Europe

57

Banking Services

Transfers/Payments

E-Banking

MulticurrencyBank Accounts

Investment Services

Execution Only

Advisory

Discretionary Asset Management

Funds in Open Architecture

Structured Products

Capital Market Products dedicated to Private

ClientsWealth Structuring

International Wealth and Tax Planning

Life Insurance

Financing

Fiduciary Services

Private Investments Vehicles

Full range of services

58

Summary

Luxembourg is a key solution of the key rule in wealth management: Geographical diversification

Luxembourg offers a wide range of attractive vehicles for individuals (and institutional) investors that can be tailored to their specific needs

Luxembourg political, legal and tax environment is stable and favorable

59

1. Shari’ah compliant investment vehicles available in Luxembourg

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Shari’ah compliant investment vehicles

Investment funds:SICAV (Investment company with variable capital)SICAF (investment company with fixed capital)FCP (unincorporated co-ownership of assets managed by a management company)

Private Equity and Venture Capital investments:

SIF (Specialised Investment Funds)

SICAR (Venture capital vehicle)

Regulated Securitisation Vehicle

Private investments:

SOPARFI (holding company)

SPF (Private family asset holding company)

Non regulated Securitisation Vehicle

Fiduciary contract

Regulated Semi-regulated Unregulated

61

2. Selection of the appropriate investment vehicle

62

Selection of the appropriate investment vehicle

Type of investor

Size of investmentIndividual investors Retail / corporate /

Institutional investors

Small size portfolio SPF SOPARFI

Medium size portfolio SIF SICAR

Large size portfolio SICAV/SICAF/FCP

63

3. Benefit from Luxembourg as a platform

64

Benefit from Luxembourg as a platform

Saudi Corporateor institutional

Investors

LuxCo

Assets or companyIn Europe

tax efficient Investment

Tax freeincome repatriation

Shari’ah compliant investments are possible

Luxembourg is used as a platform for the investments in Europe

Advantages:Tax neutrality at the level of LuxCo

Tax efficient investments

65

http://www.clker.com/clipart-men-in-black.html

3.1 Investing in Europe through a SIF

66

Investing in Europe through a SIF vehicle

Specialised Investment Funds

Sub FundMoney Market

MM

Sub FundDefensive

DEF

Sub FundReal Estate

RE

Sub FundPrivate Equity

PE

Luxe

mbo

urg

Saud

i Ara

bia


Investors

• Greater flexibility with regard to

- The investment policy (e.g. asset pooling, no restriction on eligible assets,)

- The broadening of the sphere of investors

- Single regulatory regime

• One or several managers

• Risk diversification

• Internationally well known vehicle

67


Specialised Investment Funds: legal & tax aspects

Legal Tax•The fund may be structured as a:- Common contractual fund (FCP),- Variable or fixed capital investment company (SICAV / SICAF)

At the level of the SIF•SIF are not subject to:-Corporate income tax-Municipal business tax-Net wealth tax-No withholding tax in dividend distributions and liquidation proceeds•Principle: Subscription tax of 0,01% of the net asset value of the SIF on the last day of each quarter•Exception:-Investment in other Luxembourg UCIS being subject to subscription tax-Institutional cash UCIS-Pension pooling funds-Micro finance funds-European Savings Directive applicable-VAT exemption on management services

•Possibility to set-up as an umbrella fund with multiple compartments and / or different share classes

•Shares / units are restricted to “well informed investors”

•No restriction on repayments, distributions or dividends payments

•Reduced publication & reporting duties

•The capital gain realised on the sales of the SIF units / shares by a non resident investors are not taxable in Luxembourg for non resident investors

68

SIF a necessary vehicle for wealth management

Specialised Investment Funds

Sub FundMoney Market

MM

Sub FundDefensive

DEF

Sub FundReal Estate

RE

Sub FundPrivate Equity

PE

Luxe

mbo

urg

SaudiWealth Manager

Saud

i Ara

bia

Advantages:For the customer: no bank change,

protection by the fund regulation, steady independent net asset value (NAV)

For the Wealth Manager: efficient fee handling, independent reporting and NAV, administrative time gain, so the Wealth Manager can focus on its core activities (i.e. asset management and client relationship)

Client 1

Client 2

Client 3

Bank X

Bank X

Bank X

100% of RE

50 % of MM30% of PE

20% of DEF

50% of MM50% of PE

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3.1 Structuring acquisition of European companies / real estate through Luxembourg

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Practical issues:Shari’ah compliant investments

Tax issues:Potential income taxation in Europe

(corporate income tax, income tax, net wealth tax, rental income tax)

Potential withholding tax issues

Potential capital gain taxation

In the absence of a tax efficient planning:

The return on investment will be significantly reduced

Acquisition of European companies / real estate in Europe


Investors

European located company-

Real estate located in Europe

Saud

i Ara

bia

Euro

pe

71


Structuring acquisition of European companies / real estate through Luxembourg


Investors

LuxembourgSOPARFI

Companies located in

Europe

Operational companiesFinancial assets

Real estate

Tax transparentstructureEurope

Real Estate

1- Inflows: Investments in Europe

through Luxembourg SOPARFI

• Kind of income: Dividends, rental

income, capital gains etc…

•At the level of target country:

No or reduced withholding tax

No capital gain taxation

Rental income and capital gain on

real estate are taxed in the European

target country

Euro

peta

rget

cou

ntry

Luxe

mbo

urg

Saud

i Ara

bia

Rental incomeDividendsCapital gains

SICARor

SPF

1 1

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Investors

LuxembourgSOPARFI

Company located in

Europe


Real estate


Real Estate

Luxe

mbo

urg

Saud

i Ara

bia

Rental incomeDividendsCapital gains

SICARor

SPF

2 2

2- At the level of the Luxembourg SOPARFI:

• Dividends and capital gains income received

Luxembourg Participation Exemption

regime

•Rental income is in principle not

subject to Luxembourg taxation based

on the double tax treaty concluded by

Luxembourg

Euro

peta

rget

cou

ntry

73




Investors

LuxembourgSOPARFI

Company located in

Europe


Real estate


Real Estate

Luxe

mbo

urg

Saud

i Ara

bia

Tax

neut

ralit

y

SICAR3Dividends

3- Option 1: At the level of the SICAR

SICAR is established as a resident company which is fully liable to Luxembourg income taxes

Effective tax rate might be close to 0 (under certain conditions)

No withholding tax on income distributed by the Luxembourg SOPARFI

If a SICAR is established in the form of a limited partnership, the SICAR will be considered as tax transparent entity in Luxembourg.

Euro

peta

rget

cou

ntry

74




Investors

LuxembourgSOPARFI

Company located in

Europe

Real Estate


Real Estate

Luxe

mbo

urg

Saud

i Ara

bia

Tax

neut

ralit

ySPF3Hybridinstrument

3- Option 2: At the level of the SPF• SPF (The Family Wealth Management

No withholding tax on income distributed by

Luxembourg SOPARFI

SPF is exempt from Luxembourg income

taxes

Annual subscription tax of 0,25% on its

share capital

Euro

peta

rget

cou

ntry

75




Investors

LuxembourgSOPARFI

Company located in

Europe

Real Estate


Real Estate

Luxe

mbo

urg

Saud

i Ara

bia

SICARor

SPF

4Dividends

Liquidation proceeds4- Repatriation of income to the Saudi investors•Income distribution from SICAR or SPF

No withholding tax on dividends distributionNo withholding tax on liquidation proceeds

•At the level of the Saudi investors

The structuring could be realised pursuant to the Shari’ah law

Efficient investmentPeriodic income flows

4

Euro

peta

rget

cou

ntry

76


Shari’ah investments in Europe are recommended to be realised through Luxembourg

Using Luxembourg as gateway or hub provides:

Access to European market, European directives (i.e. EU Parent / Subsidiary) and to Luxembourg extensive treaty networkLegal and regulatory flexibility (attractive vehicles for High Net Worth Individuals and Family Offices) Tax neutrality and certainty in LuxembourgTax efficiency at the level of target country

Summary: Luxembourg is the leading wealth management center in Eurozone

77

Thank you!www.lff.lu

Economy & Finance

Presentation Financial Seminar Riyadh Final