Using luxembourg in international structures

Using Luxembourg in

international structures

Kiev - December 2012

BDO Luxembourg – Philippe PONSARD

General considerations

Luxembourg : General considerations

Hamburg 2011 - Tax Conference - Inbound Investment into Europe from North

America

Page 3

Central position in the heart of Europe

Top level financial center

2nd in the World for domiciled funds

(behind the United States)

Multi-cultural and expert workforce

Highly qualitative infrastructure and

good logistical network

Supportive and welcoming authorities

Favorable tax environment

Economic, social and political stability

ensuring a secure legal and tax

framework

International players with operations in Luxembourg

Page 4

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http://www.kn-portal.com/index.html

http://www.guardian.com/en/index.html

../../../..

http://www1.dupont.com/NASApp/dupontglobal/corp/index.jsp

Luxembourg fund industry at a glance

3 705 Investment funds

13 030 fund units

€ 2,208 billion in Assets under Management

More than 46 000 distribution agreements for Luxembourg

UCITS

Figures as at February 28, 2011 – Sources: ALFI / CSSF / LuxembourgforFinance

Peru 93%

Chile 79%

South Korea 100%

Japan 62%

Taiwan 76%

Hong Kong 78%

Singapore 74%

Bahrain 81%

Sweden 75%

Germany 70%

Switzerland 73%

France 72%

Luxembourg investment funds :a unique brand Luxembourg market share of foreign funds registered for

sale

Sources: LuxembourgforFinance

Luxembourg : a favorable tax environment

Page 7

No withholding tax on royalties, interest & liquidation proceeds

No withholding tax on dividends paid to tax treaty corporation if 10%

shareholding or acquisition price > € 1.2m. and 12 months holding period

Maximum withholding tax on dividends : 15%

Participation exemption : total exemption for dividends and capital gains

income if 10% shareholding or acquisition price of € 1.2 m. for dividends / €

6m. for capital gains and 12 months holding period

An 80% exemption for net income deriving from certain IP rights and capital

gains realized on the sale of IP

No or minor taxation upon exit or refinancing strategy

No CFC rules

Access to EU Directives (Parents/Subsidiary, Interest/Royalties, and Merger

Directives)

64 double tax treaties (latest treaties : Hong Kong, Bahrain, Qatar, ...)

Lowest VAT rate in the European Union (standard rate : 15%)

Ruling practice and stable law environment

Luxembourg DDT network

3

4

1

6

7

8

10 9

12

11

14

13

17

16

18

19

20

22 23

24 25

26

27

28

29

30

31

32

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34

35

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44

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46

48

49

50

51 52

47 53

60

2

58

68

59

56

55

15 54

62

63

65

57

70

71

75

5 21

72

Double tax treaties in force (Bahrain, UAE, Qatar)

Double tax treaties pending (Kuwait, Saudi Arabia, Lebanon, Syria)

41

73 61

67

74 64 69

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. Poland

35. Portugal 36. Romania 37. Russia 38. San Marino 40. Slovakia 41. Slovenia 43. Spain

44. Sweden 45. Switzerland 49. Turkey 50. UK 52. Uzbekistan 55. Georgia 57. Moldavia

59. Cyprus 61. Albania 62. Kazakhstan 64. Kyrgyzstan 66. Liechtenstein 67. Macedonia 69. Monaco

72. Serbia 74. Armenia 75. Ukraine

04. Brazil

06. Canada

29. Mexico

47. Trinidad & Tobago

51. United States

60. Argentina

68. Barbados

20. Israel

28. Mauritius

31. Morocco

56. U.A.E.

42. South Africa

48. Tunisia

54. India

58. Bahrain

71. Qatar

63. Kuwait

65. Lebanon

70. Pakistan

73. Syria

66

No double tax treaty

Sources: LuxembourgforFinance

Tax treaty

Page 9

No tax treaty currently in force with Ukraine

Treaty voted in Luxembourg in 2001

Typical structures

• Directly or indirectly (through patrimonial vehicle)

held by a limited number of private shareholders

• Not subject to any tax in Luxembourg (only

registration duty of 0,25% of the share capital)

• No withholding tax on dividends paid without

condition

• Does not enjoy the benefits of the EU Directives

or DTTs

• Cannot grant remunarated loans

Page 11

Indiv or HoldCo

Lux SPF

Securities of any

kind

Typical Structures:

Private wealth management company (SPF) Investments in securities

Capital Dividends

Dividends,

interest, etc

• No withholding tax on dividends paid to tax treaty

parent company if :

- 10% ownership or acquisition price of EUR 1.2m

- 12 month holding period

• Full exemption on incoming dividends and capital

gains (participation exemption regime) if

- 10% ownership or acquisition price > € 1.2m

(dividends)/ € 6m (capital gains)

- 12 month holding period

- If EU subsidiary subject to tax or non EU sub.

taxed at an effective rate > 10,5%

• In general, no or low foreign withholding tax on

incoming dividends from EU/ non-EU subsidiaries

pursuant to EU Directive and tax treaties

Page 12

HoldCo

(DTT country)

LuxCo

EU / non-EU

Typical Structures: Holding (SOPARFI) EU or non-EU Subsidiaries

Capital

Capital

Dividends

Dividends

Typical Structures: Holding & Financing Optimization through use of hybrid Instruments

Financing Luxembourg entities

Page 13

ParentCo

LuxCo

Foreign Subs

Tracking

hybrid

loans

Capital

Dividends

Dividends

Capital

Loan

Description:

• Parent funds LuxCo with an hybrid instrument

• Hybrid instrument is equity for Parent tax purposes

and debt for LuxCo tax purposes

• LuxCo uses proceeds to fund subs or to acquire assets

Benefits:

• Income on hybrid loan treated as tax deductible

interest expense at level of LuxCo

• Only taxation of small spread at the level of LuxCo

(subject to confirmation of the Luxembourg tax

authorities based on TP study)

• No withholding tax from LuxCo to Parent

• Certainty through tax clearance

Debt qualification in Luxembourg if :

• (Low) Interest rate accruing even in case of

losses

• Variable interest based on profits before tax

• No stapling provision

• No entitlement to voting rights

• Preferably not convertible into shares

• No entitlement to participation in liquidation

proceeds or hidden reserves,

• Short term (i.e. <49 years)

• Ranking prior to capital

No single factor is decisive. A comprehensive

analysis is required. Tax agreement needed to

secure tax treatment in Luxembourg


Page 14

Typical Structures: Hybrid instruments Debt qualification in Luxembourg

Foreign Entity

LuxCo

Hybrid

instrument Interest /

dividend

Assets Assets

Assets

Capital

Tested Hybrid Instruments (treated as debt for

Luxembourg tax purposes) :

• Profit Participating Loan (“PPL”) / Asset linked

note (“ALN”)

Used to repatriate income to an investment fund (real estate

investment fund, private equity fund, …), a private holding

company, …

• Convertible Loan Note (“CLN”)

• Preferred Equity Certificates (“PEC") or

Convertible Preferred Equity Certificates

(“CPEC”)

Treated as debt in commercial balance sheet. Used mainly

to repatriate income to the USA

• Mandatory Redeemable Preference Shares

(“MRPS”)

Treated as capital in commercial balance sheet but debt for

tax purposes. Allows to show a strong balance sheet

(important when third party funding is required). Tried and

tested with Canada and Sweden.


Page 15

Typical Structures: Hybrid instruments Debt qualification in Luxembourg

Foreign Entity

LuxCo

Hybrid

instrument Interest /

dividend

Assets Assets

Assets

Background:

• Yield under CPEC linked to profitability of underlying

investments. Very low taxable margin in Luxembourg.

• Conversion feature allowing increase in the fair value of the

instrument if appreciation of underlying investments

• CPEC treated as equity in US / debt for Luxembourg tax

purposes

Benefits:

• Tax deduction in Luxembourg as interest accrue (no

obligation to pay the yield before exit)

• No Lux WHT on interest payments

• Exit strategy :

- no conversion but buy-back at the greater of FMV (of the

shares at the time of the conversion) or principal amount

- offset of taxable gain on investment by loss from buy-

back of instrument

- No Luxembourg WHT

• Not subject to US tax until repatriation

• Debt push down to OpCos without incurring US taxable

income Page 16

Typical Structures: Hybrid instruments Convertible Preferred Equity Certificates

ForeignCo

LuxCo

Op COs

CPEC

Capital

Dividends

Dividends

Capital

Loan

Main characteristics:

• Shares from legal perspective (debt for Lux. tax).

Dividend distribution decided by AGM

• No (or very limited) voting rights

• Mandatory redemption at end of a fixed term (max. 10

years)

• Redeemable at option of issuer at any time

• Preferential right to reimbursement at maturity

• Fixed and/or variable preferred cumulative dividend

• No participation in net profits realized by the company in

liquidation but participation in liquidation gain of

determined activity or asset possible

• MRPS may not represent more than half of share capital

(share premium excluded). Ratio of 50/50 constitutes a

legal requirement (voting shares/non voting shares) but

most part of the MRPS financing can be made by an

increase of the share premium account


America

Page 17

Typical Structures: Hybrid instruments Mandatory Redeemable Preference Shares

ForeignCo

LuxCo

Foreign Subs

MRPS

Capital Dividends Loan

Dividends

Background:

• Conditions to be met in order to obtain a binding

APA from the Luxembourg tax authorities

• APA obtained before 28.01.2011 were valid until

01.01.2012

Considerations :

• Equity at risk : lesser of 1% or EUR 2 mio

• Level of substance in Luxembourg

• TP study in line with the OECD guidelines (not

mandatory but the Luxembourg tax authorities

may challenge the remuneration earned by the

taxpayer in absence of such documentation)

Page 18

Typical Structures: Financing activity Intragroup financing activity – Transfer Pricing Circulars

Parent Co

LuxCo

Subsidiary

Capital

Capital

Loan

Third Party

Loan Loan

No withholding tax on interest paid by LuxCo

If orphan structure : not subject to Luxembourg TP rules

Page 19

Typical Structures: Financing activity Bonds issued through Luxembourg

Dutch Stichting

LuxCo Beneficiary

Company

Loan Bond

Interest Interest

Investors

Luxembourg tax consideration:

• Redemption of entire class of shares followed by

cancelation is not subject to withholding tax

• Disposal by non residents of important (10%)

shareholding in a LuxCo more than 6 months after

acquisition is not taxable

Other considerations:

• Max 10 classes of shares

• Classes of shares should not track the yearly

income

• Fair market value of shares depends on all assets

and liabilities of LuxCo (no segregation of assets to

determine the value of a specific class of shares)

• Specific remuneration attached to a class of shares

• Issue of classes of shares should be provided in the

by-laws

• Capital gain tax treatment at the level of the

shareholder to be considered


America

Page 20

Other repatriation technique Repatriation through share buy-backs

ParentCo

LuxCo

Op CO

Capital

Up to 10

classes of

shares

Op CO Op CO

Op CO

Background

• Existing Company re-domiciles to

Luxembourg

Benefits

• Access to EU Directives, extensive tax

planning opportunities, …

• Opening tax balance sheet

- Reserves and profit brought forward :

treated as capital for tax purposes

- Step-up of assets/liabilities :

reevaluation reserve treated as capital

for tax purposes

- Possibility to activate a goodwill

Amortization of goodwill will reduce

future taxable income


America

Page 21

Increase / Transfer of activities to Luxembourg Migration & Step-up in value

LuxCo ForeignCo

Foreign Subs Foreign Subs

Increase / Transfer of activities to Luxembourg Tax intangible asset amortisation

Background

• Intangible assets can be recognized in case

transfer of business/support from Group company

to Luxembourg (know-how, clientele,…)

Benefit

• Only recognized and amortized in tax balance

sheet

• Annual depreciation is tax-deductible and reduce

corporate tax basis

Considerations

• Potential recognition of deferred tax asset

consolidated account

• Net wealth tax applies on intangible assets

• Tax agreement needed to secure tax benefits


America

Page 22

“business

opportunity” 100 %

Foreign

Country

Luxembourg

Group Co

LuxCo

Luxembourg IP Box

Application

• 80% exemption of net positive income received

in consideration for use of, or right to use any

qualifying IP

• 80% exemption of capital gain on the disposal of

qualifying IP

• Effective CIT rate : 5.76%

• 100% net wealth tax exemption

Considerations

• Only for creation or acquisition of the IP after

31.12.07

• Anti-abuse rules (for acquisition of IP from

related company)

• Recapture rules at the time of the disposal of

the IP (when costs have been fully deducted)

Gaming industry takes advantage of the regime

(Innova, Kabam, Nexon, Onlive, ...)


America

Page 23

ParentCo

LuxCo

Patent

Software

copyright

Trade

mark

Domain

name

Design &

model

IP

Luxembourg Securitization vehicle

If non tax transparent (SCA, SA, Sàrl):

• Subject to corporate income tax and trade tax

• But payments (or commitment to pay) to investors are

always deductible even if under Company Law, they take

the form of dividend distributions. Hence:

• No withholding tax on dividends distributed by SV

• Any payment (or commitment to pay) is deductible

from the tax basis

• Exempt from net wealth tax

• Resident for tax treaty purposes (Luxembourg position)

• No withholding tax on dividend from LuxCo to SV

If tax transparent (Securitization Fund) :

• SV considered not to carry out a commercial activity in

Luxembourg : non resident partners not taxable in

Luxembourg

• No withholding tax on distributions


America

Page 24

Luxembourg SV

Securitised

assets

Unrestricted

investor


America

Page 25

Real estate investment in Europe Through Luxembourg vehicles

ParentCo /

Investment vehicle

LuxCo

Local SPV

PPL / MRPS

/ CPEC Capital

LuxCo Lux PropCo

French SCI

/SAS

Lux PropCo

Germany UK

Interest /

dividends

France

Country X

Loan Loan Loan Loan

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http://www.vectorart.com/webart/products/53471M.GIF

Real estate investment in Europe Through Luxembourg vehicles

• Investing in French real estate through a French SCI /SAS owned by a

Luxembourg LuxCo : in case of sale of French SCI / SAS by LuxCo, capital

gain should neither be taxable in France nor in Luxembourg*

• Investing in German real estate through a Luxembourg company:

possibility to avoid trade tax on rental income and capital gain (in case of

direct sale of property)

• Investing in UK real estate through a Luxembourg company : no capital

gain tax on the sale of the property

• Investing in other countries through a SPV owned by a Luxembourg

company : possibility to finance the SPV with a shareholder loan.

Possibility to sell the SPV (in general, the tax treaty gives the right to tax

to Luxembourg)

*Tax treaty between Luxembourg and France may change in the coming months

Page 26

Luxembourg – a leading European real estate hub


America

Page 27

Aberdeen AM

AMB

Amundi AM

Axa REIM

Aviva Investors

BlackRock CBRE

Investors

Fidelity

First State

Franklin Templeton

Goodman

Heitman Hines

ING

JP Morgan AM

LaSalle IM

MGPA

Morgan Stanley

Pacific Star

Pramerica

Prologis

Schroders

SEB AM

Tishman Speyer

UBS

(…)

Source : Luxembourg For Finance

Available investment fund structures

Regulation

UCITS

Part I UCI

Part II SIF

All type of Asset

Class

Asset Class:

limited

SICAR

SV SOPARFI

Asset Class: Strictly

limited

Flexibility

Asset Class:

VC & PE

CSSF Depositary Bank

Auditor Regulati

on & Safety



America

Page 29

Private equity investments in Europe Through a Luxembourg SICAR, a SIF or a Soparfi

SICAR / SIF / Sop

Luxembourg SCA

LuxCo 1 LuxCo 2 LuxCo 3

NewCo

LuxCo 4

Germany Poland Country X

Bonds / convertible

bonds

NewCo NewCo NewCo

France

GP LuxCo

Investors

Advisors

Management fees

/ carried interest

Advisory

fees

Managers

Private equity investments in Europe Tax regime of Luxembourg SICAR

If non tax transparent (SCA, SA, Sàrl):

• Subject to corporate income tax and trade tax

• But exemption for all income and capital gains deriving

from

• Investments in transferable securities

• Temporary cash investment pending their investment in

risk capital

• No withholding tax on dividends distributed by SICAR


• Considered by Luxembourg as a resident for tax treaty

purposes

• No withholding tax on dividend from LuxCo to SICAR

If tax transparent (SCS) :

• SICAR considered not to carry out a commercial activity in

Luxembourg : non resident partners are not taxable in

Luxembourg

• No withholding tax on distributions


America

Page 30

Luxembourg

SICAR

NewCo

Lux SPV

Qualified

investor

Private equity investments in Europe Luxembourg Specialized Investment Fund (SIF)

Main tax aspects :

• Not subject to corporate income tax and trade tax

• Subscription tax: 0.01% instead of 0.05% for normal

funds

• No withholding tax on dividends distributed by SIF


• 15 % WHT on dividend from LuxCo to SIF but no WHT on

interest payments

Main regulatory aspects :

• Minimum share capital of €1.25m

• Custodian Bank/Auditors required

• Possible forms: SICAV, SICAF or FCP

• Risk spreading requirements

Page 31

Luxembourg

SIF

NewCo

Lux SPV

Qualified

investor

Loan

Luxembourg – a leading European private equity hub


America

Page 32

3i

American Capital

Apax Partners

Bain Capital

BC Partners Carlyle Group

Cinven

Coller Capital

CVC

Fortress Goldman Sachs

Investcorp

JP Morgan

KKR

Kreditanstalt für Wiederaufbau

(KfW) Lazard

LGT Capital Partners

Oaktree Capital

PAI Partners

TPG Unicapital

Warburg Pincus

(…)


Luxembourg – a leading European “regulated”

hedge funds hub


America

Page 33

Aberdeen AM

Alliance Bernstein

BlackRock

BlueBay Asset Management

Crédit Agricole

Crédit Suisse

Deutsche Bank

Fidelity

GLG

Goldman Sachs

HSBC

ING

Invesco

JP Morgan

LCF Rothschild

Lyxor

MAN

Morgan Stanley

Permal

Pioneer Investments

Transtrend

UBS

(…)



America

Page 34

Appendix

Luxembourg investment vehicles:

comparative table

UCITS UCIs SICAR SIF SV SPF SOPARFI

Entity type SICAV (SA)

FCP

SICAV (SA)

SICAF (SA,

SCA, SARL)

FCP

Corporate (SA,

SCA, SARL,

SCOSA) or

transparent

SCS

SICAV/F

(SA, SCA,

SARL, SCOSA)

FCP

Other

(fiduciary)

Corporate

(SA, SCA,

SARL,

SCOSA)

Fund (FCP or

on a fiduciary

basis)

Corporate

(SA, SCA,

SARL,

SCOSA)

Corporate

(SA, SCA,

SARL,

SCOSA,

European

company)

Minimum capital /

net assets

requirements (in

EUR)

€1,250,000

(within 6

months of the

approval)

€1,250,000

(within 6

months of the

approval)

€1,000,000

(within 12

months of the

approval)

€1,250,000

(within 12

months of the

approval)

SA/SCA

€31,000

SARL

€12,500

SA/SCA

€31,000

SARL

€12,500

SA/SCA

€31,000

SARL

€12,500

Capital (fixed /

variable) Variable

Fixed or

variable

Fixed or

variable

Fixed or

variable

Fixed for sec.

companies Fixed Fixed

Segregated sub-

funds Yes Yes Yes Yes Yes No No

Distribution of

dividends : any

restriction (except

compliance with the

min cap / NAV

requirement)

No restriction

No restriction No restriction

No restriction

(except for

interim

distributions

and for SICAF)

No restriction

for funds

(except for

corporate)

Yes Yes

Luxembourg investment vehicles

Source : Luxembourg For Finance Page 35


Tax regime on

ordinary income,

capital gains, etc..

Fully exempt Fully exempt

Fully taxable

but exempt on

qualifying

securities and

transit funds

Fully exempt

Fully taxable

but

commitments

paid to

investors are

deductible

Fully exempt

under

conditions

Fully taxable

but benefits

from large

exemption,

tax credit and

tax incentive

Is tax transparent

form available? Yes Yes Yes Yes Yes No No

Any WHT on

dividends to

investors?

No No No No No No

No if eligible

DTT

corporate

investors

Treaty / EU

Directives

access?

No, except for

SICAV/F (50%

DTT access)

No, except for

SICAV/F (50%

DTT access)

Yes (case by

case)

No, except for

SICAV/F (50%

DTT access)

Yes (case by

case) No Yes

Other tax

considerations?

Small annual

subscription tax

on the NAV

(0,05% max) with

exemptions /

reductions

available

Small annual

subscription tax

on the NAV

(0,05% max) with

exemptions /

reductions

available

N/A

Small annual

subscription

tax on the

NAV (0,01%

max) with

exemptions

available

N/A

Subscription

tax of 0,25%

on the capital,

SP, and debt

> 8 times SC

and SP with a

max of

125.000 per

year

Net worth tax

of 0,5% per

year with

exemption

available


Page 36 Source : Luxembourg For Finance



Eligible investors Unrestricted Unrestricted well informed well informed Unrestricted

Individual,

private estate

management

entities or

intermediary

Unrestricted

Eligible assets /

strategies

Transferrable

securities and / or

other liquid

financial assets

Unrestricted

All types of PE / VC

(including RE PE)

and temporary

investments in

other assets

Unrestricted

Securitization

of risks linked

to any type of

assets or 1/3

party

obligations

Private

financial assets Unrestricted

Restrictions Borrowing and

high

diversification

Risk

diversification

requirements (in

principle,

investment < 20%

NAV)

Qualifying

investments

Risk

diversification

requirement

(30% NAV)

No active

management of

assets

No controlling

activity over

investments

No

Offer of securities

to investors

Subject to CSSF

approval

Subject to CSSF

approval

Subject to CSSF

approval

Subject to

CSSF approval

(with a

possibility to

launch before

approval)

Unrestricted if

non regulated

Not subject to

CSSF approval

Not subject to

CSSF approval

Pag e 37 Source : Luxembourg For Finance


Promoter (financial

institutions with

sufficient financial

means)

Yes Yes No No No N/A N/A

Investment manager

(experience and

reputation)

Yes Yes No No No N/A N/A

Directors / managers

(experience and

reputation)

Yes Yes Yes Yes N/A if non reg N/A N/A

Offering documents

Yes

Yes Yes Yes N/A if non reg N/A N/A

AOA or Man Reg Yes Yes Yes Yes N/A if non reg N/A N/A

Independent Auditor Yes Yes Yes Yes N/A if non reg N/A N/A

Custodian Yes Yes Yes Yes N/A if non reg N/A N/A

Central

administration in

Lux

Yes Yes Yes Yes N/A if non reg N/A N/A


Page 38 Source : Luxembourg For Finance

BDO Luxembourg

BDO Luxembourg : a one-stop shop

International tax advice

(corporate, VAT, individual income tax, …)

+ Setting-up and administration of all types of investment

vehicles through our specialized subsidiaries

(CF Corporate Services and CF Fund Services)

CF Corporate Services: “all-in” package

• Incorporation of companies, including contacts with banks

and notaries

• Provision of registered office

• Directorship mandates

• Bookkeeping, legal formalities, secretarial

• Tax compliance

• Statutory auditor

Philippe PONSARD

Partner CF Corporate Services

Experience

Philippe joined BDO in 1999.

He is one of the four partners of CF Corporate Services, the legal entity of BDO Luxembourg

specialised in financial engineering and domiciliation and administration of companies.

He is in charge of a portfolio of 200 companies and his clientele is made of entrepreneurs, HNWI,

private equity funds and large corporate groups from all over the world.

Professional Affiliations

Member of the Ordre des Expert Comptable (Chartered Accoutants Association)

Member of the OEC Domiciliation Committee

Member of the OEC Anti Money Laundering Advisory Committee

Education

Ingénieur commercial, I.A.G., U.C.L., Belgium

Areas of

Specialization:

Corporate and

Trust Services

Domiciliation and

administration of

Luxembourg

entities

Page 42

Phone: +352 45123-357

Email:

[email protected]

LUXEMBOURG

Economy & Finance

Using luxembourg in international structures