1. Using Luxembourg in
international structures
Kiev - December 2012
BDO Luxembourg – Philippe PONSARD

2. General considerations

3. Luxembourg : General considerations

Central position in the heart of Europe

Top level financial center

2nd in the World for domiciled funds
(behind the United States)

Multi-cultural and expert workforce

Highly qualitative infrastructure and
good logistical network

Supportive and welcoming authorities

Favorable tax environment

Economic, social and political stability
ensuring a secure legal and tax
framework
Hamburg 2011 - Tax Conference - Inbound Investment into Europe from North
America
Page 3

4. International players with operations in Luxembourg
Page 4

5. Luxembourg fund industry at a glance
 3 705 Investment funds
 13 030 fund units
 € 2,208 billion in Assets under Management
 More than 46 000 distribution agreements for Luxembourg
UCITS
Figures as at February 28, 2011 – Sources: ALFI / CSSF / LuxembourgforFinance

6. Luxembourg investment funds :a unique brand
Luxembourg market share of foreign funds registered for
sale
Sweden 75%
Germany 70%
South Korea 100%
Switzerland 73%
France 72%
Japan 62%
Taiwan 76%
Bahrain 81%
Hong Kong 78%
Peru 93%
Singapore 74%
Chile 79%
Sources: LuxembourgforFinance

7. Luxembourg : a favorable tax environment

No withholding tax on royalties, interest & liquidation proceeds

No withholding tax on dividends paid to tax treaty corporation if 10%
shareholding or acquisition price > € 1.2m. and 12 months holding period

Maximum withholding tax on dividends : 15%

Participation exemption : total exemption for dividends and capital gains
income if 10% shareholding or acquisition price of € 1.2 m. for dividends / €
6m. for capital gains and 12 months holding period

An 80% exemption for net income deriving from certain IP rights and capital
gains realized on the sale of IP

No or minor taxation upon exit or refinancing strategy

No CFC rules

Access to EU Directives (Parents/Subsidiary, Interest/Royalties, and Merger
Directives)

64 double tax treaties (latest treaties : Hong Kong, Bahrain, Qatar, ...)

Lowest VAT rate in the European Union (standard rate : 15%)

Ruling practice and stable law environment
Page 7

8. Luxembourg DDT network
01. Austria
11. Finland
21. Italy
35. Portugal
44. Sweden
59. Cyprus
72. Serbia
02. Azerbaijan
12. France
24. Latvia
36. Romania
45. Switzerland
61. Albania
74. Armenia
03. Belgium
13. Germany
25. Lithuania
37. Russia
49. Turkey
62. Kazakhstan
75. Ukraine
05. Bulgaria
14. Greece
27. Malta
38. San Marino
50. UK
64. Kyrgyzstan
17
Brazil
Canada
Mexico
Trinidad & Tobago
United States
9
32
3
40
45
1
57
51
38
72
60. Argentina
68. Barbados
44
33
6
04.
06.
29.
47.
51.
08. Czech Rep.
16. Hungary
32. Netherlands
40. Slovakia
52. Uzbekistan
66. Liechtenstein
19
12
35
31
43
34
8
75
16
41 36
66
69
21
14
5
62
55
49 74
30
52
2
23
7
70
73
63
67
68
47
64
48 27
61
29
56
54
15
46
58
53
71
26
39
65
Double tax treaties in force
(Bahrain, UAE, Qatar)
Double tax treaties pending
(Kuwait, Saudi Arabia, Lebanon, Syria)
59
20
4
28
No double tax treaty
10. Estonia
19. Ireland
34. Poland
43. Spain
57. Moldavia
69. Monaco
37
11 10
24
25
13
50
09. Denmark
17. Iceland
33. Norway
41. Slovenia
55. Georgia
67. Macedonia
42
60
Sources: LuxembourgforFinance
18
22
20.
28.
31.
56.
42.
48.
54.
58.
71.
Israel
Mauritius
Morocco
U.A.E.
South Africa
Tunisia
India
Bahrain
Qatar
63.
65.
70.
73.
Kuwait
Lebanon
Pakistan
Syria

9. Tax treaty
No tax treaty currently in force with Ukraine
Treaty voted in Luxembourg in 2001
Page 9

10. Typical structures

11. Typical Structures:
Private wealth management company (SPF)
Investments in securities
Indiv or HoldCo
•
Capital
Lux SPF
Dividends,
interest, etc
Securities of any
kind
Page 11
•
Not subject to any tax in Luxembourg (only
registration duty of 0,25% of the share capital)
•
Dividends
Directly or indirectly (through patrimonial vehicle)
held by a limited number of private shareholders
No withholding tax on dividends paid without
condition
•
Does not enjoy the benefits of the EU Directives
or DTTs
•
Cannot grant remunarated loans

12. Typical Structures: Holding (SOPARFI)
EU or non-EU Subsidiaries
HoldCo
(DTT country)
No withholding tax on dividends paid to tax treaty
parent company if :
- 10% ownership or acquisition price of EUR 1.2m
- 12 month holding period
•
Capital
•
Full exemption on incoming dividends and capital
gains (participation exemption regime) if
- 10% ownership or acquisition price > € 1.2m
(dividends)/ € 6m (capital gains)
- 12 month holding period
- If EU subsidiary subject to tax or non EU sub.
taxed at an effective rate > 10,5%
•
In general, no or low foreign withholding tax on
incoming dividends from EU/ non-EU subsidiaries
pursuant to EU Directive and tax treaties
Dividends
LuxCo
Capital
Dividends
EU / non-EU
Page 12

13. Financing Luxembourg entities
Typical Structures: Holding & Financing
Optimization through use of hybrid Instruments
Tracking
hybrid
loans
ParentCo
Capital
Dividends
LuxCo
Loan
Capital
Dividends
Foreign Subs
Page 13
Description:
• Parent funds LuxCo with an hybrid instrument
• Hybrid instrument is equity for Parent tax purposes
and debt for LuxCo tax purposes
• LuxCo uses proceeds to fund subs or to acquire assets
Benefits:
• Income on hybrid loan treated as tax deductible
interest expense at level of LuxCo
• Only taxation of small spread at the level of LuxCo
(subject to confirmation of the Luxembourg tax
authorities based on TP study)
• No withholding tax from LuxCo to Parent
• Certainty through tax clearance

14. Financing Luxembourg entities
Typical Structures: Hybrid instruments
Debt qualification in Luxembourg
Debt qualification in Luxembourg if :
LuxCo
Assets
Assets
Assets
Page 14
Interest /
dividend
Variable interest based on profits before tax
•
No stapling provision
No entitlement to voting rights
•
Preferably not convertible into shares
•
Capital
(Low) Interest rate accruing even in case of
losses
•
Hybrid
instrument
•
•
Foreign Entity
No entitlement to participation in liquidation
proceeds or hidden reserves,
•
Short term (i.e. <49 years)
•
Ranking prior to capital
No single factor is decisive. A comprehensive
analysis is required. Tax agreement needed to
secure tax treatment in Luxembourg

15. Financing Luxembourg entities
Typical Structures: Hybrid instruments
Debt qualification in Luxembourg
Tested Hybrid Instruments (treated as debt for
Luxembourg tax purposes) :
Foreign Entity
Hybrid
instrument
Interest /
dividend
LuxCo
•
Profit Participating Loan (“PPL”) / Asset linked
note (“ALN”)
Used to repatriate income to an investment fund (real estate
investment fund, private equity fund, …), a private holding
company, …
•
•
Convertible Loan Note (“CLN”)
Preferred Equity Certificates (“PEC") or
Convertible Preferred Equity Certificates
(“CPEC”)
Treated as debt in commercial balance sheet. Used mainly
to repatriate income to the USA
Assets
Assets
Assets
Page 15
•
Mandatory Redeemable Preference Shares
(“MRPS”)
Treated as capital in commercial balance sheet but debt for
tax purposes. Allows to show a strong balance sheet
(important when third party funding is required). Tried and
tested with Canada and Sweden.

16. Typical Structures: Hybrid instruments
Convertible Preferred Equity Certificates
ForeignCo
CPEC
Capital
Dividends
LuxCo
Loan
Capital
Op COs
Page 16
Dividends
Background:
• Yield under CPEC linked to profitability of underlying
investments. Very low taxable margin in Luxembourg.
• Conversion feature allowing increase in the fair value of the
instrument if appreciation of underlying investments
• CPEC treated as equity in US / debt for Luxembourg tax
purposes
Benefits:
• Tax deduction in Luxembourg as interest accrue (no
obligation to pay the yield before exit)
• No Lux WHT on interest payments
• Exit strategy :
- no conversion but buy-back at the greater of FMV (of the
shares at the time of the conversion) or principal amount
- offset of taxable gain on investment by loss from buyback of instrument
- No Luxembourg WHT
• Not subject to US tax until repatriation
• Debt push down to OpCos without incurring US taxable
income

17. Typical Structures: Hybrid instruments
Mandatory Redeemable Preference Shares
Main characteristics:
ForeignCo
MRPS
Dividends
LuxCo
Loan
Capital
Dividends
Foreign Subs
• Shares from legal perspective (debt for Lux. tax).
Dividend distribution decided by AGM
• No (or very limited) voting rights
• Mandatory redemption at end of a fixed term (max. 10
years)
• Redeemable at option of issuer at any time
• Preferential right to reimbursement at maturity
• Fixed and/or variable preferred cumulative dividend
• No participation in net profits realized by the company in
liquidation but participation in liquidation gain of
determined activity or asset possible
• MRPS may not represent more than half of share capital
(share premium excluded). Ratio of 50/50 constitutes a
legal requirement (voting shares/non voting shares) but
most part of the MRPS financing can be made by an
increase of the share premium account
Hamburg 2011 - Tax Conference - Inbound Investment into Europe from North
America
Page 17

18. Typical Structures: Financing activity
Intragroup financing activity – Transfer Pricing Circulars
Parent Co
Loan
Third Party
Capital
LuxCo
Loan
Capital
Subsidiary
Page 18
Loan
Background:
• Conditions to be met in order to obtain a binding
APA from the Luxembourg tax authorities
• APA obtained before 28.01.2011 were valid until
01.01.2012
Considerations :
• Equity at risk : lesser of 1% or EUR 2 mio
• Level of substance in Luxembourg
• TP study in line with the OECD guidelines (not
mandatory but the Luxembourg tax authorities
may challenge the remuneration earned by the
taxpayer in absence of such documentation)

19. Typical Structures: Financing activity
Bonds issued through Luxembourg
Dutch Stichting
Bond
Investors
Loan
LuxCo
Interest
No withholding tax on interest paid by LuxCo
If orphan structure : not subject to Luxembourg TP rules
Page 19
Interest
Beneficiary
Company

20. Other repatriation technique
Repatriation through share buy-backs
Luxembourg tax consideration:
• Redemption of entire class of shares followed by
cancelation is not subject to withholding tax
• Disposal by non residents of important (10%)
shareholding in a LuxCo more than 6 months after
acquisition is not taxable
ParentCo
Up to 10
classes of
shares
Other considerations:
LuxCo
Capital
Op CO
Op CO
Op CO
Op CO
• Max 10 classes of shares
• Classes of shares should not track the yearly
income
• Fair market value of shares depends on all assets
and liabilities of LuxCo (no segregation of assets to
determine the value of a specific class of shares)
• Specific remuneration attached to a class of shares
• Issue of classes of shares should be provided in the
by-laws
• Capital gain tax treatment at the level of the
shareholder to be considered
Hamburg 2011 - Tax Conference - Inbound Investment into Europe from North
America
Page 20

21. Increase / Transfer of activities to Luxembourg
Migration & Step-up in value
Background
• Existing Company re-domiciles to
Luxembourg
ForeignCo
LuxCo
Foreign Subs
Foreign Subs
Benefits
• Access to EU Directives, extensive tax
planning opportunities, …
• Opening tax balance sheet
- Reserves and profit brought forward :
treated as capital for tax purposes
- Step-up of assets/liabilities :
reevaluation reserve treated as capital
for tax purposes
- Possibility to activate a goodwill
Amortization of goodwill will reduce
future taxable income
Hamburg 2011 - Tax Conference - Inbound Investment into Europe from North
America
Page 21

22. Increase / Transfer of activities to Luxembourg
Tax intangible asset amortisation
Foreign
Country
Group Co
“business
opportunity”
100 %
LuxCo
Luxembourg
Background
• Intangible assets can be recognized in case
transfer of business/support from Group company
to Luxembourg (know-how, clientele,…)
Benefit
• Only recognized and amortized in tax balance
sheet
• Annual depreciation is tax-deductible and reduce
corporate tax basis
Considerations
• Potential recognition of deferred tax asset
consolidated account
• Net wealth tax applies on intangible assets
• Tax agreement needed to secure tax benefits
Hamburg 2011 - Tax Conference - Inbound Investment into Europe from North
America
Page 22

23. Luxembourg IP Box
Application
• 80% exemption of net positive income received
in consideration for use of, or right to use any
qualifying IP
• 80% exemption of capital gain on the disposal of
qualifying IP
• Effective CIT rate : 5.76%
• 100% net wealth tax exemption
ParentCo
LuxCo
IP
Domain
name
Patent
Design &
model
Trade
mark
Software
copyright
Considerations
• Only for creation or acquisition of the IP after
31.12.07
• Anti-abuse rules (for acquisition of IP from
related company)
• Recapture rules at the time of the disposal of
the IP (when costs have been fully deducted)
Gaming industry takes advantage of the regime
(Innova, Kabam, Nexon, Onlive, ...)
Hamburg 2011 - Tax Conference - Inbound Investment into Europe from North
America
Page 23

24. Luxembourg Securitization vehicle
Unrestricted
investor
Luxembourg SV
Securitised
assets
If non tax transparent (SCA, SA, Sàrl):
• Subject to corporate income tax and trade tax
• But payments (or commitment to pay) to investors are
always deductible even if under Company Law, they take
the form of dividend distributions. Hence:
• No withholding tax on dividends distributed by SV
• Any payment (or commitment to pay) is deductible
from the tax basis
• Exempt from net wealth tax
• Resident for tax treaty purposes (Luxembourg position)
• No withholding tax on dividend from LuxCo to SV
If tax transparent (Securitization Fund) :
• SV considered not to carry out a commercial activity in
Luxembourg : non resident partners not taxable in
Luxembourg
• No withholding tax on distributions
Hamburg 2011 - Tax Conference - Inbound Investment into Europe from North
America
Page 24

25. Real estate investment in Europe
Through Luxembourg vehicles
PPL / MRPS
/ CPEC
ParentCo /
Investment vehicle
Capital
Interest /
dividends
LuxCo
Loan
Loan
Local SPV
Loan
Loan
LuxCo
Lux PropCo
Lux PropCo
French SCI
/SAS
Country X
Germany
UK
France
Hamburg 2011 - Tax Conference - Inbound Investment into Europe from North
Page 25
America

26. Real estate investment in Europe
Through Luxembourg vehicles
•
Investing in French real estate through a French SCI /SAS owned by a
Luxembourg LuxCo : in case of sale of French SCI / SAS by LuxCo, capital
gain should neither be taxable in France nor in Luxembourg*
•
Investing in German real estate through a Luxembourg company:
possibility to avoid trade tax on rental income and capital gain (in case of
direct sale of property)
•
Investing in UK real estate through a Luxembourg company : no capital
gain tax on the sale of the property
•
Investing in other countries through a SPV owned by a Luxembourg
company : possibility to finance the SPV with a shareholder loan.
Possibility to sell the SPV (in general, the tax treaty gives the right to tax
to Luxembourg)
*Tax treaty between Luxembourg and France may change in the coming months
Page 26

27. Luxembourg – a leading European real estate hub
Aberdeen
AM
Heitman
Hines
Tishman
Speyer
UBS
AMB
Goodman
ING
SEB AM
(…)
Amundi AM
Franklin
Templeton
JP Morgan
AM
Schroders
Axa REIM
First State
LaSalle IM
Prologis
Aviva
Investors
Fidelity
MGPA
Pramerica
BlackRock
CBRE
Investors
Morgan
Stanley
Pacific
Star
Source : Luxembourg For Finance
Hamburg 2011 - Tax Conference - Inbound Investment into Europe from North
America
Page 27

28. Available investment fund structures
Deposita
ry Bank
CSSF
Regulati
on &
Safety
Auditor
Asset Class: Strictly
limited
Asset Class:
limited
Regulation
UCITS
Part I
SICAR
UCI
Part II
SIF
SOPARFI
All type of Asset
Class
Source : Luxembourg For Finance
Asset Class:
VC & PE
SV
Flexibility

29. Private equity investments in Europe
Through a Luxembourg SICAR, a SIF or a Soparfi
Managers
Investors
Advisors
Bonds / convertible
bonds
SICAR / SIF / Sop
Luxembourg SCA
GP LuxCo
Management fees
/ carried interest
LuxCo 1
LuxCo 2
LuxCo 3
LuxCo 4
NewCo
NewCo
NewCo
NewCo
Country X
France
Germany
Poland
Hamburg 2011 - Tax Conference - Inbound Investment into Europe from North
America
Page 29
Advisory
fees

30. Private equity investments in Europe
Tax regime of Luxembourg SICAR
Qualified
investor
Luxembourg
SICAR
Lux SPV
NewCo
If non tax transparent (SCA, SA, Sàrl):
• Subject to corporate income tax and trade tax
• But exemption for all income and capital gains deriving
from
• Investments in transferable securities
• Temporary cash investment pending their investment in
risk capital
• No withholding tax on dividends distributed by SICAR
• Exempt from net wealth tax
• Considered by Luxembourg as a resident for tax treaty
purposes
• No withholding tax on dividend from LuxCo to SICAR
If tax transparent (SCS) :
• SICAR considered not to carry out a commercial activity in
Luxembourg : non resident partners are not taxable in
Luxembourg
• No withholding tax on distributions
Hamburg 2011 - Tax Conference - Inbound Investment into Europe from North
America
Page 30

31. Private equity investments in Europe
Luxembourg Specialized Investment Fund (SIF)
Qualified
investor
Luxembourg
SIF
Loan
Lux SPV
NewCo
Page 31
Main tax aspects :
• Not subject to corporate income tax and trade tax
• Subscription tax: 0.01% instead of 0.05% for normal
funds
• No withholding tax on dividends distributed by SIF
• Exempt from net wealth tax
• 15 % WHT on dividend from LuxCo to SIF but no WHT on
interest payments
Main regulatory aspects :
• Minimum share capital of €1.25m
• Custodian Bank/Auditors required
• Possible forms: SICAV, SICAF or FCP
• Risk spreading requirements

32. Luxembourg – a leading European private equity hub
3i
Fortress
Goldman Sachs
TPG
Unicapital
American
Capital
CVC
Investcorp
PAI Partners
Warburg Pincus
Apax Partners
Coller Capital
JP Morgan
Oaktree Capital
(…)
Bain Capital
Cinven
KKR
LGT Capital
Partners
BC Partners
Carlyle Group
Kreditanstalt für
Wiederaufbau
(KfW)
Lazard
Source : Luxembourg For Finance
Hamburg 2011 - Tax Conference - Inbound Investment into Europe from North
America
Page 32

33. Luxembourg – a leading European “regulated”
hedge funds hub
Aberdeen AM
Goldman
Sachs
HSBC
Pioneer
Investments
Transtrend
Alliance
Bernstein
GLG
ING
Permal
UBS
BlackRock
Fidelity
Invesco
Morgan
Stanley
(…)
BlueBay Asset
Management
Deutsche
Bank
JP Morgan
MAN
Crédit
Agricole
Crédit Suisse
LCF
Rothschild
Lyxor
Source : Luxembourg For Finance
Hamburg 2011 - Tax Conference - Inbound Investment into Europe from North
America
Page 33

34. Appendix
Luxembourg investment vehicles:
comparative table
Hamburg 2011 - Tax Conference - Inbound Investment into Europe from North
America
Page 34

35. Luxembourg investment vehicles
UCITS
Corporate (SA,
SCA, SARL,
SCOSA) or
transparent
SCS
(SA, SCA,
SARL, SCOSA)
FCP
FCP
SICAR
SICAV (SA)
SICAV (SA)
SICAF (SA,
SCA, SARL)
SIF
SV
SICAV/F
Entity type
UCIs
Corporate
(SA, SCA,
SARL,
SCOSA)
FCP
Other
(fiduciary)
Fund (FCP or
on a fiduciary
basis)
SPF
SOPARFI
Corporate
(SA, SCA,
SARL,
SCOSA)
Corporate
(SA, SCA,
SARL,
SCOSA,
European
company)
Minimum capital /
net assets
requirements (in
EUR)
€1,250,000
(within 6
months of the
approval)
€1,250,000
(within 6
months of the
approval)
€1,000,000
(within 12
months of the
approval)
€1,250,000
(within 12
months of the
approval)
SA/SCA
SA/SCA
SA/SCA
€31,000
€31,000
€31,000
SARL
SARL
SARL
€12,500
€12,500
€12,500
Capital (fixed /
variable)
Variable
Fixed or
variable
Fixed or
variable
Fixed or
variable
Fixed for sec.
companies
Fixed
Fixed
Segregated subfunds
Yes
Yes
Yes
Yes
Yes
No
No
No restriction
No restriction
(except for
interim
distributions
and for SICAF)
No restriction
for funds
(except for
corporate)
Yes
Yes
Distribution of
dividends : any
restriction (except
compliance with the
min cap / NAV
requirement)
Page 35
No restriction
No restriction
Source : Luxembourg For Finance

36. Luxembourg investment vehicles
UCITS
UCIs
SICAR
Tax regime on
ordinary income,
capital gains, etc..
Fully exempt
Fully exempt
Fully taxable
but exempt on
qualifying
securities and
transit funds
Is tax transparent
form available?
Yes
Yes
Yes
SIF
SV
SPF
SOPARFI
Fully exempt
Fully taxable
but
commitments
paid to
investors are
deductible
Fully exempt
under
conditions
Fully taxable
but benefits
from large
exemption,
tax credit and
tax incentive
Yes
Yes
No
No
Any WHT on
dividends to
investors?
No
No
No
No
No
No
No if eligible
DTT
corporate
investors
Treaty / EU
Directives
access?
No, except for
SICAV/F (50%
DTT access)
No, except for
SICAV/F (50%
DTT access)
Yes (case by
case)
No, except for
SICAV/F (50%
DTT access)
Yes (case by
case)
No
Yes
Other tax
considerations?
Small annual
subscription tax
on the NAV
(0,05% max) with
exemptions /
reductions
available
Small annual
subscription tax
on the NAV
(0,05% max) with
exemptions /
reductions
available
N/A
Subscription
tax of 0,25%
on the capital,
SP, and debt
> 8 times SC
and SP with a
max of
125.000 per
year
Net worth tax
of 0,5% per
year with
exemption
available
Page 36
N/A
Source : Luxembourg For Finance
Small annual
subscription
tax on the
NAV (0,01%
max) with
exemptions
available

37. Luxembourg investment vehicles
UCITS
Eligible investors
Unrestricted
Eligible assets /
strategies
Restrictions
Offer of securities
to investors
Pag e 37
UCIs
SICAR
Unrestricted
well informed
Transferrable
securities and / or
other liquid
financial assets
Unrestricted
All types of PE / VC
(including RE PE)
and temporary
investments in
other assets
Borrowing and
high
diversification
Risk
diversification
requirements (in
principle,
investment < 20%
NAV)
Subject to CSSF
approval
Subject to CSSF
approval
Qualifying
investments
Subject to CSSF
approval
Source : Luxembourg For Finance
SIF
SV
SPF
SOPARFI
well informed
Unrestricted
Individual,
private estate
management
entities or
intermediary
Unrestricted
Unrestricted
Securitization
of risks linked
to any type of
assets or 1/3
party
obligations
Private
financial assets
Unrestricted
No active
management of
assets
No controlling
activity over
investments
No
Unrestricted if
non regulated
Not subject to
CSSF approval
Not subject to
CSSF approval
Risk
diversification
requirement
(30% NAV)
Subject to
CSSF approval
(with a
possibility to
launch before
approval)

38. Luxembourg investment vehicles
UCITS
UCIs
SICAR
SIF
SV
SPF
SOPARFI
Promoter (financial
institutions with
sufficient financial
means)
Yes
Yes
No
No
No
N/A
N/A
Investment manager
(experience and
reputation)
Yes
Yes
No
No
No
N/A
N/A
Directors / managers
(experience and
reputation)
Yes
Yes
Yes
Yes
N/A if non reg
N/A
N/A
Offering documents
Yes
Yes
Yes
Yes
N/A if non reg
N/A
N/A
AOA or Man Reg
Yes
Yes
Yes
Yes
N/A if non reg
N/A
N/A
Independent Auditor
Yes
Yes
Yes
Yes
N/A if non reg
N/A
N/A
Custodian
Yes
Yes
Yes
Yes
N/A if non reg
N/A
N/A
Central
administration in
Lux
Yes
Yes
Yes
Yes
N/A if non reg
N/A
N/A
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Source : Luxembourg For Finance

39. BDO Luxembourg

40. BDO Luxembourg : a one-stop shop
International tax advice
(corporate, VAT, individual income tax, …)
+
Setting-up and administration of all types of investment
vehicles through our specialized subsidiaries
(CF Corporate Services and CF Fund Services)

41. CF Corporate Services:
“all-in” package
• Incorporation of companies, including contacts with banks
and notaries
• Provision of registered office
• Directorship mandates
• Bookkeeping, legal formalities, secretarial
• Tax compliance
• Statutory auditor

42. Philippe PONSARD
LUXEMBOURG
Partner CF Corporate Services
Experience
Philippe joined BDO in 1999.
He is one of the four partners of CF Corporate Services, the legal entity of BDO Luxembourg
specialised in financial engineering and domiciliation and administration of companies.
He is in charge of a portfolio of 200 companies and his clientele is made of entrepreneurs, HNWI,
private equity funds and large corporate groups from all over the world.
Areas of
Specialization:
Corporate and
Trust Services
Domiciliation and
administration of
Luxembourg
entities
Phone: +352 45123-357
Email:
philippe.ponsard@cfcorporate.lu
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Professional Affiliations
Member of the Ordre des Expert Comptable (Chartered Accoutants Association)
Member of the OEC Domiciliation Committee
Member of the OEC Anti Money Laundering Advisory Committee
Education
Ingénieur commercial, I.A.G., U.C.L., Belgium