Investment Case Studies
CASE STUDY 1 – REGULATED VEHICLES
Advantages of the structure: Low subscription tax of 0,01%; No wealth tax; Low minimum required capital; 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:
- private individuals managing their own private wealth; or
- 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
- intermediaries (including fiduciaries) acting on behalf of the persons listed under (i) and (ii) above.
CASE STUDY 8 - MASTER-FEEDER WITH TAX ADVANTAGES
Advantages of the structure: Full tax efficiency; Consolidation of various portfolios into one entity; Investor comfort and regulatory supervision for private investors; Convenient investor management; Cost efficiency
ThaCap LTEE is an independent advisor specialized in fiduciary, fund structuring, governance, investments and capital raising. The team has an average of 20 years of experience in international banking, investment funds and asset management, both in EMEA, the Americas and Asia-Pacific.
BRN No: C22192707