Wealth Protection Plan - Permanent Establishment under Luxembourg Law - Private Placement in Luxembourg

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Corporate, Funds and Family office

Family Office - Wealth Protection Plan - HNWI - Wealth Structuring - Inheritance Planning

Corporate - Permanent Establishment - Company Redomiciliation - Luxembourg Tax

Funds - Private Placements - Securitisation - SIF - SICAR - Security Issuance


Wealth Protection Plan

High Net Worth Individuals around the world are dealing or are invested in many type of assets and businesses.

HNWI have people around them they want to protect or to whom they want part or all of their assets to be transferred if anything happens.

Few have put in place an organised structure, a proper retirement plan, a dedicated inheritance program to insure the continuity of their affairs, their businesses and incomes for the next generation.

Creatrust has put together a package of services called the Wealth Protection Plan at the destination of HWNI wishing to be helped in the set-up of such a plan for retirement and/or succession.

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Read Also :

  Foundation Constitution and Structuring

  Wealth Manager Selection in Luxembourg and abroad

  Luxembourg Real Estate Vehicles



Permanent Establishment under the Luxembourg Law

A Permanent Establishment (PE) is any installation or facility which is fixed to a definite location and which serves the operation of an established business. Some examples are given by the law:

place of management of the business;

branch offices, manufacturing establishments, warehouses, purchasing, sales, or other offices, and all other facilities which serve the owner or co-owner of the business, or his permanent representative, such as a manager, in the conduct of the business; or

building or construction projects, if the duration of the individual project or that of several connected projects carried out in the same community exceeds, or is likely to exceed, 6 months.

There is no specific guidance by the Luxembourg tax authorities for the interpretation of the above, and, in practice, Luxembourg case law often refers to the commentary on the OECD Model Convention for the prevention of double taxation between States. If there are double taxation treaties concluded between Luxembourg and other countries, generally each of such tax treaties provides a definition of PE. Such definition takes precedence over national law.


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Read Also :

  Permanent Establishment

  Company Re-domiciliation

  Services/International Tax advisory



Private Placement in Luxembourg

Public offers, subject to exemptions, are deemed to be “private placements”:

Issuance of securities under the Prospectus Law - Securities, offered to the public or admitted to trading on a regulated market, are governed by the amended law. Prospectuses for securities, including drawing-up, approval and distribution of the prospectus, have to be published (three different prospectus regimes). Approval of the prospectus will be done both by the CSSF and by the Luxembourg Stock Exchange.

Issuance of shares in the frame of a SIF or a SICAR to well-informed investors, being an institutional investor or a professional investor, and

any investor, adhering to the status of well-informed investor and either, investing a minimum of EUR 125.000 in the vehicle or

any investor being subject to an assessment by a professional Wealth/Asset Manager certifying his expertise, his experience and his knowledge in the SIF/SICAR and its underlying investments.

Issuance of securities via a Securitisation Vehicle - Unregulated securitisation vehicles do not need to be supervised by the CSSF if they do issue bonds, shares, notes, units or certificates to well informed investors or to the public but issuing securities with a value of more than EUR 125.000, and less than 4 times per year (both conditions are cumulative).

Request our related Creavision

Read Also

  Securitisation Vehicle and Security Issuance

  Specialised Investment Fund - SIF

  Capital Risk Fund -SICAR



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> Securitisation of Real Estate - Luxembourg Residence Permit Solution for HNWI - Obtaining a Tax Agreement in Luxembourg

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

> Minimum Income Tax for collective entities - Individual versus collective investment vehicles - Luxembourg Step Up principle

> 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

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