Your trusted tax advisor for investment funds in Luxembourg

From structuring and compliance to international reporting and CSSF audits, we provide end-to-end tax advisory designed to protect, optimize, and future-proof your fund tax operations.

Structuring and Setup of Investment Vehicles

➤ Tax Structuring of Funds and Companies

We advise on the design and implementation of tax-efficient investment structures, ensuring both fiscal optimization and full compliance with Luxembourg and EU regulations.

Our services include:

  • Analysis of the most suitable vehicle (SICAV, FCP, SIF, RAIF, SCSp, SOPARFI, SPF, etc.).

  • Definition of the most efficient holding chain for investors and asset portfolios.

  • Review of double tax treaties applicable to your investment jurisdictions.

  • BEPS and substance analysis to ensure economic substance and regulatory compliance in Luxembourg.

➤ Setup and Management of Holdings

  • Incorporation and registration of Luxembourg holding companies (SOPARFI).

  • Advisory on the taxation of dividends, interest, and capital gains (participation exemption, anti-hybrid rules, etc.).

  • Optimization of capital and intra-group financing structures.

  • Coordination with authorities and preparation of annual corporate tax filings.

➤ Tax Planning and Optimization

  • Assessment of effective tax burden on fund or holding income.

  • Simulation of investment and distribution flows.

  • Withholding tax reclaims in Europe and third countries.

  • Advice on carried interest and sponsor taxation.

  • Implementation of OECD- and EU-compliant tax optimization mechanisms.

Tax Compliance and Regulatory Obligations

➤ Luxembourg Tax Declarations and Compliance

  • Subscription tax: calculation, exemption review, and quarterly filings.

  • VAT: analysis of fund management service qualification, preparation, and filing of returns.

  • Corporate Income Tax (CIT) and Municipal Business Tax (MBT): full assistance for taxable entities.

➤ International Reporting and Automatic Exchange of Information

  • FATCA / CRS: identification of reportable accounts, preparation, and electronic filing.

  • Investor tax reporting: preparation of investor reports (Germany, Austria, UK, Switzerland, etc.) in line with local formats.

  • Withholding tax reporting: management of tax reclaims and documentation.

  • Financial Transaction Tax (FTT): impact analysis and compliance reporting.

➤ DAC6, DAC7, DAC8 and Regulatory Monitoring

  • DAC6: identification, documentation, and reporting of cross-border tax arrangements.

  • DAC7: advisory on new digital platform reporting obligations and transparency requirements.

  • DAC8: compliance with new crypto-asset reporting and disclosure rules.

  • Continuous regulatory watch: proactive updates and strategic advice on legislative or tax changes impacting investment structures.

➤ AML/TAX Directives and CSSF Requirements

  • Implementation of AML/TAX directives issued by the CSSF and the European Commission.

  • Assessment of tax and AML risks associated with investors or managed entities.

  • Drafting and updating of internal compliance policies (AML/KYC, substance, tax governance).

  • Training sessions for internal teams on Luxembourg tax and regulatory frameworks.

Tax Audit Support and Regulatory Assistance

➤ Tax Audit and Investigation Support

  • Full assistance during Luxembourg tax audits conducted by the Administration des Contributions Directes.

  • Review of tax documentation and drafting of official responses to the authorities.

  • Negotiation and management of tax positions with the Luxembourg tax administration.

  • Representation and coordination with auditors, legal counsel, and foreign tax authorities.

➤ CSSF Reviews and Regulatory Communication

  • Assistance during CSSF reviews or inspections, particularly on tax, AML, substance, or reporting topics.

  • Preparation of supporting documentation and tax files required by the CSSF.

  • Strategic advice to align internal practices with CSSF guidance and regulatory expectations.

➤ Tax Due Diligence and Audits

  • Comprehensive tax due diligence during mergers, acquisitions, or restructurings.

  • Identification of fiscal, regulatory, and reputational risks.

  • Review of FATCA, CRS, DAC6, and VAT reporting compliance.

  • Tax governance audits and recommendations for process improvement.

We transform tax complexity into clarity, efficient, and cost-effective process for you