In a global economy, international holding structures have become vital for investors to meet the everchanging economic challenges and to survive on competitive international markets. In many international groups, for private equity firms and for many high-net-worth individuals, holding companies are at the cornerstone of the business and tax management of their investments.
Luxembourg is a major holding location used by multinationals and international investors for structuring their investments.Luxembourg holding structures have been used successfully by thousands of investors for decades. Yet, the fiscal legislation applying to them is in constant evolution, both from a Luxembourg and an international tax standpoint, and the efficient use of Luxembourg holding companies has nowadays become full of difficulties and pitfalls.
1. Why do we use holding structures?
2. How to finance them in a tax efficient manner?
3. What are the latest anti-avoidance rules developed that may threaten a Luxembourg holding company?
4. How are holding structures impacted by the DAC6 legislation on aggressive tax planning and could be impacted by the future Unshell proposal of EU Directive (ATAD3)?
Olivier dal Farra is a lawyer focusing on international taxation in a global law firm. Olivier’s practice focuses on international tax planning and tax advice. He assists international clients including foreign asset managers and private equity firms in tax structuring strategies concerning their debt or equity investments, and in connection with merger and acquisition transactions. He is also active within the private wealth sector and advises wealthy families and financial institutions on tax planning and international tax compliance aspects, especially on matters relevant to Luxembourg holding companies.