Investment Case Studies
CASE STUDY 1 – REGULATED VEHICLES (SIF, PART II UCI)
Advantages of the structure: Low subscription tax of 0,01%; No wealth tax; Minimum required capital of EUR 1,25M; Diversified portfolio; Cost efficiency; Possibility of listing; No income tax.
CASE STUDY 2 – MASTER-FEEDER RAIF SET-UP OF A TAILOR-MADE VEHICLE SCHEME
Advantages of the structure: No subscription tax at Feeder level; Separate AGM; Consolidation of various portfolios into one entity; Investor comfort and regulatory supervision for private investors; Convenient investor management; Cost efficiency
CASE STUDY 3 – MULTI-JURISDICTIONAL VEHICLE SCHEME SET-UP OF A TAILOR-MADE PARALLEL STRUCTURE
Advantages of the structure: Marketing passport ensured by the AIFMD; Access to EU market space granted to US Investment Managers; Joint investment process
CASE STUDY 4 – RESPONSIBLY SOURCED ESG NOTE (issuing process)
Advantages of the structure: Consolidating a pool of assets and offering the entire portfolio to investors; Funding an investment by raising capital together with other investors; Unrestricted eligibility of investors; Economy of scale; No subscription tax; No wealth tax
CASE STUDY 5 – RENTAL OF AN INDIRECTLY REGULATED VEHICLE
Advantages of the structure: Low set-up fees, as rental; No wealth tax; No minimum required capital; Usage of an established structure; Unlimited types of investment strategies.
CASE STUDY 6 – SPECIAL LIMITED PARTNERSHIP (SLP)
Advantages of the structure: The Special Limited Partnerships (SLPs) are used to invest in all types of assets, as a special purpose vehicle (SPV), a co-investment entity for institutional investors or co-ownership between family offices, wealthy individuals and other entities; No risk diversification; No minimum capital requirement
CASE STUDY 7 – SPF (PRIVATE WEALTH MANAGEMENT COMPANY)
The Luxembourg private wealth management company (hereafter: SPF – société de gestion de patrimoine familial), governed by the Law of 11 May 2007, is a private wealth management vehicle which enables individuals to structure their estate in a simple, flexible, unregulated and tax-efficient manner and for numerous purposes, thereby appealing to various types of investors. Ultimately, with Luxembourg being a highly developed centre of legal and financial services, private individuals willing to structure their asset holdings from an end-to-end perspective, have all their expectations met.
Main characteristics and benefits of the SPF:
- Private character and design – certainty regarding co-investor(s) and targeted approach to risk allocation
- Separate legal personality – limited liability
- Advantages of a holding company instead of a direct placement of capital for private individuals
- Flexibility in investment structuring
- Simplified and attractive taxation and incorporation – low share capital requirements
Eligible investors are either:
- private individuals managing their own private wealth; or
- private wealth management entities acting exclusively for the estate of one or more individuals, which may be resident and non-resident entities, such as foundations, trusts or stichtings. The eligibility of those entities is interpreted in a wide sense, with their sole purpose required to be the management of assets of one or more physical persons; or
- intermediaries (including fiduciaries) acting on behalf of the persons listed under (i) and (ii) above.