ATOZ and Garrigues briefing - Cross-border fund structuring: Tax insights from Luxembourg and Portugal
Lisbon - Portugal
With a challenging year 2024 behind them, alternative market players continue to navigate significant hurdles into early 2025. In the current financial market environment, co-investments, continuation funds, and secondary transactions have solidified their importance within the alternative investment fund sector. Now more than ever, selecting the right jurisdiction for fund domicile and carefully structuring underlying investments are critical to addressing these evolving challenges.
With its stable political and legal framework, Luxembourg remains a favoured jurisdiction for establishing investment platforms for asset managers. The continued growth in assets under management reaffirms investors’ confidence in Luxembourg-based funds, underscoring the jurisdiction’s appeal in meeting the demands of today’s dynamic investment landscape.
Portugal offers not only high-yield investment opportunities across a variety of asset classes and strategies, but it has also developed a legal and tax landscape which preserves investment value and stability. Portuguese UCITS and alternative investment funds, including immovable property funds, venture capital funds, securitization vehicles and, more recently, loan funds, in addition to
the key features of their respective regulatory and tax regimes, offer a competitive international tax and legal engagement, particularly with Luxembourg.
The purpose of this session is to explore the features attached to a Luxembourg-Portuguese investment strategy through different types of structures and platforms, while identifying the key risk areas, such as beneficial ownership, economic substance and hybrid mismatches, that should be contemplated by investors and Clients.
After an overview of the Luxembourg fund landscape including the recent tax developments in this field as well of the specific considerations when investing into Portugal, ATOZ Tax Advisers Partners, Petya Dimitrova, Fanny Bueb and Antoine Dupuis, Garrigues Portugal Partners, Miguel Pimentel and António Pedro Braga, and Principal Associate José Diogo Mègre Pires, will discuss and explain some typical Luxembourg - Portuguese structuring opportunities for Real Estate, Private Equity, Infrastructure, Venture capital and Debt investments and introduce recent or planned changes in the field.
Our speakers will discuss:
· Luxembourg fund landscape and recent tax updates
· Specific consideration when investing into Portugal
· HoldCo - Portuguese REIF structure for real estate in Portugal
· HoldCo / PropCo structures Luxembourg Portugal - Substance & BO considerations
· Private equity / Infrastructure typical investments structures
· Debt funds and securitisation vehicles - Typical structures
The event will begin with registration and welcome coffee at 8:30 a.m., followed by the briefing at 9:00 a.m.
Location
Garrigues Lisbon
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