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.
08-09-2022Dutch Supreme Court refers case on Dutch interest deduction limitation to Court of Justice of the European Union for potential breach of EU lawIn its ruling of 2 September 2022, the Dutch Supreme Court asks the Court of Justice of the European Union (CJ) to clarify whether the Dutch interest deduction limitation rule to prevent base erosion infringes the EU treaty freedoms.
22-07-2022Dutch Supreme Court provides guidance on interest deduction limitation rules in Private Equity structuresOn 15 July 2022, the Dutch Supreme Court ruled in two cases that the tax deduction of interest payments made by a Dutch group to its private equity investors is not denied under the specific interest deduction limitation rule to prevent base erosion.
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
This Q&A provides practical guidance on how US MNEs can navigate the recent developments introduced by Pillar Two.
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).
13-07-2022CBRE Investment Management has merged its European Industrial Fund and Logistics Venture Fund to form Europe Logistics PartnersLoyens & Loeff has acted as lead tax counsel and assisted CBRE Investment Management (“CBRE IM”) with the merger of its European Industrial Fund and Logistics Venture Fund which has been rebranded into Europe Logistics Partners (“ELP”) and has been r
24-02-2021Loyens & Loeff advised on the Luxembourg aspects of the largest ESG-linked subscription credit facility in the United StatesLoyens & Loeff Luxembourg advised Bank of America in relation to the ESG-linked subscription credit facility to certain investment funds managed by The Carlyle Group.