Fund Tax Services

At Leroy & Goldbach, our expertise covers the full spectrum of Luxembourg and cross-border taxation, including the following areas:

Tax Structures for Alternative Investment Funds (AIFs including RAIFs)

Tax planning for  AIFs including  RAIFs, including subscription tax exemptions and VAT management to enhance fund attractiveness.

Carried Interest Structuring

Designing tax efficient carried interest vehicles and incentive plans for fund managers (GPs), optimising tax treatment under Luxembourg law while ensuring compliance with ATAD, OECD guidelines, and EU directives. We focus on tax-efficient allocation of performance fees, leveraging partnerships like SCSp for transparency and reduced withholding taxes.

Debt and Equity Markets

Advisory on tax implications of issuances, including withholding tax relief and hybrid instrument qualification for optimal financing.

Employee Incentives and Benefits

Structuring stock options, phantom shares, and profit-sharing schemes with favourable tax regimes for executives in fund management companies.

Estate Planning

Tailored strategies for HNWIs and family offices, incorporating trusts and succession planning to minimise inheritance and gift taxes.

M&A and Corporate Reorganisation

Tax-efficient advice on mergers, demergers and recapitalisations, including step-up in basis and the fiscal unity regime.

Private Equity

Optimisation for PE funds, including carried interest, management fees, and exit strategies with double tax treaty benefits.

Real Estate Taxation

Guidance on REIFs and property transactions, including VAT, transfer taxes, and depreciation rules for efficient holdings.

Structured Finance and Securitisations

Tax-neutral set-ups for securitisation vehicles, with attention to the interest limitation rule and the minimum net wealth tax.

Tax Litigation

Representation in disputes with tax authorities, including appeals and negotiations for favourable resolutions.

Taxation of IP Rights

Strategies for IP boxes, royalty structures, and R&D incentives under Luxembourg's IP regime.

Transfer Pricing Strategy and Related OECD-Compliant Documentation

Development of arm's-length policies, benchmarking, and documentation to comply with BEPS standards.

Indirect Tax Matters

Expertise in VAT, real estate transfer taxes, subscription taxes, and registration duties for seamless operations.