Investment Management Deal Structuring
Together with our Corporate / M&A team and Real Estate team, our Investment Management team advises fund managers worldwide on legal and tax aspects of private equity backed investments, in listed and non-listed entities and in real estate in our home countries.
We also see more and more (institutional) investors teaming up with asset managers in club deals or separate accounts, or in alternative forms such as SPACs. The commercial terms and the legal and tax structure are often very similar to those of private equity funds. Therefore, these are a natural fit with our ‘traditional’ investment management work.
The anti-hybrid mismatch rules of the EU Anti-Tax Avoidance Directive (ATAD2) aim to prevent situations of a double deduction and a deduction without a corresponding inclusion of the income at the level of the recipient resulting from a hybrid mismat
Luxembourg is the main jurisdiction in Europe for launching credit funds with a European strategy.
Implementing Pillar One & Pillar Two
To adapt international tax rules to an increasingly digitalised economy, the OECD/G20 Inclusive Framework proposes a two-pillar overhaul of the existing system as from 2023/2024. Tax directors and their teams can already model the impact and assess o
On 25 January, Loyens & Loeff submitted input on OECD’s Public Consultation Document on Amount B of Pillar One.
Substance & Tax Law
In recent years tax authorities have placed more emphasis on combatting the use of abusive and aggressive tax structures by companies operating across borders, to ensure fair taxation.
The European Commission recently issued a new proposal (ATAD 3)
Recently, the European Parliament (EP) almost unanimously adopted an opinion suggesting changes to the draft anti-shell Directive (ATAD3).