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

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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


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


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


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 :


  Hybrid Instruments

  Alternative Investment Funds




Latest news

> Special Limited Partnership - Securitisation for IP projects - Private Foundation in Luxembourg

> Private Placement in Luxembourg - Foreign Permanent Establishment - Luxembourg Private Foundation

> Permanent Establishment in Luxembourg - Loi Propectus - Brochure Family Office Services

> "Modified Nexus Approach" - Securitisation for IP projects - Resident Permit Solution for HNWI

> Certificate of Tax Residence for Funds - EU: High Quality Securitisation - Private Assets Consolidation

> Tax treatment of the Limited Partnership - Securitisation for Real Estate projects - Common Reporting Standard (2016)

> Obtaining a Tax Agreement in Luxembourg – Refinancing assets via Securitisation – Wealth Protection Plan

> New ruling in Luxembourg - VAT rate - "Bearer Shares2 - Structuring art collection

> European member states anti-hybrid loan mismatches - Prospectus for the securities your issue via Luxembourg

   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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