Raising Capital via Luxembourg - SLP Tax treatment - Structuring Private Equity investment and funds

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 23/07/2015


Latest news Luxembourg


Corporate, Funds and Family office


Family Office - Bond Issuance - Securitisation Vehicle - Raising Capital - Hybrid Instruments


Corporate - Special Limited Partnership (SLP) - Permanent Establishment - Luxembourg Taxation


Funds - Private Equity Funds - Private Equity Investment - SOPARFI - Debt Instruments - Bonds - PEC/CPEC




FAMILY OFFICE


Raising Capital via Luxembourg


How does a company attract new capital, especially a smaller one? By issuing equity? Equity is a common way to attract new investors. Yet, equity also provides the investors with a share in the overall returns and potentially even decision influence or even control over a company.


With the Creatrust turnkey solution for bond issuance, it is now possible to issue bonds and hybrid instruments for smaller and medium-sized enterprises as well. It used to be possible to issue bonds only for capital needs in excess of EUR 50 million. Creatrust offers solutions from as little as EUR 1 million and with lead times of several weeks only.


The issuance is structured through a securitisation vehicle, i.e. we securitise an activity or act as a first lender to the company in need of capital.


The Bond issuance is then subscribed by potential investors who then receive a yield which depends on the risk and value of the underlying company or assets.


Request our brochure on Raising Capital via Luxembourg


 


Read Also:


  Bond Issuance


  Securitisation Undertakings


  Structured products Issuance




 CORPORATE


Special Limited Partnership Tax treatment


Limited Partnerships are treated as “tax transparent” with respect to corporate tax purposes, in most cases…Some Partnerships are deemed not taxable in Luxembourg (eg. holding shares in a foreign private equity deal, holding a yacht/plane, an estate abroad, a portfolio of securities, in Luxembourg or abroad):


If the partnership is managed by a General Partner, resident in Luxembourg or not, private individual or company (if it holds less than 5% in the Partnership’ share capital), then profits are not taxable in Luxembourg at all.


The management of private assets (being movable or immovable) by a Partnership, held by private individuals, stays a private asset management and is not taxable in the hands of its Partners.


There is no attractivity of a Permanent Establishment in Luxembourg. This means that any activities, realised by the Partnership outside of the Luxembourg ground, or realised through a permanent establishment abroad (or deemed to be realised abroad under the terms of a double tax treaty), will not be considered attached to the Luxembourg permanent establishment and thus will not be taxable in Luxembourg.


The profits derived from Commercial Activities realised through a Partnership, which does not have a permanent establishment on the Luxembourg ground, are not taxable in Luxembourg.


 Alternative Investment Fund, regulated or non regulated, which are managed from Luxembourg are not taxable.


Read more




Read Also :


  Corporate services


  Fund services


  International Tax advisory




FUNDS


Luxembourg: reputable location for structuring private equity investments and private equity funds


Investors, Promoters, Private Equity Firms, Family Office who choose Luxembourg as a base for their private equity structure will have different available solutions.


SOPARFI, which is a vehicle dedicated to private equity deals. It can acquire private equity investments, in an efficient tax manner with a minimal legal and administrative burden.


Issuance of any type of debt intruments, making easy the financing of such deals like: (Convertible) Preferred Equity Certificates (PEC/CPEC), Subordinated Notes, Convertible Bonds, Bonds, Warrants, Tracker Certificates.any other debt instruments.


Read more on Private Equity




Read Also :


  SOPARFI


  Hybrid Instruments


  Alternative Investment Funds


 


 


 CONTACT US


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   Becoming a resident in Luxembourg


> New V.A.T. - The advance tax decision or Rulings -Three processes to subscribe in securities - Refinancing asset through securisation


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