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:
  1. private individuals managing their own private wealth; or
  2. 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
  3. intermediaries (including fiduciaries) acting on behalf of the persons listed under (i) and (ii) above.

    Thales Capital Luxembourg is a licensed, independent advisor specialized in private capital management, fund structuring, governance, investments and capital raising.

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