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Tax advantaged benefits of investing in Luxembourg

Tax advantaged benefits of investing in Luxembourg

While many life settlement funds are based offshore for favorable tax treatment, a recent IRS tax ruling on withholding tax has established Luxembourg as the premiere domicile for such funds.

About Luxembourg FCP’s

A Luxembourg FCP is considered as being a tax transparent entity in Luxembourg. A tax transparent entity is an entity which is not taxed either in representative capacity or in its own capacity as a tax paying entity, but the tax is levied on the investors, in their domicile, on their share of income in the entity.
Aside from being considered tax transparent from a Luxembourg perspective, care should be given to the acknowledgement of the tax transparency of the FCP by respectively:

• The tax authorities of the investor’s home jurisdiction (domicile);
• The tax authorities of investment country (USA), which may levy withholding taxes on income and/or gains arising on investments held by the FCP.

 

 

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