Using Luxembourg in international structures Kiev - December 2012 BDO Luxembourg – Philippe PONSARD
Aug 17, 2014
Using Luxembourg in
international structures
Kiev - December 2012
BDO Luxembourg – Philippe PONSARD
General considerations
Luxembourg : General considerations
Hamburg 2011 - Tax Conference - Inbound Investment into Europe from North
America
Page 3
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
International players with operations in Luxembourg
Page 4
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
Peru 93%
Chile 79%
South Korea 100%
Japan 62%
Taiwan 76%
Hong Kong 78%
Singapore 74%
Bahrain 81%
Sweden 75%
Germany 70%
Switzerland 73%
France 72%
Luxembourg investment funds :a unique brand Luxembourg market share of foreign funds registered for
sale
Sources: LuxembourgforFinance
Luxembourg : a favorable tax environment
Page 7
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
Luxembourg DDT network
3
4
1
6
7
8
10 9
12
11
14
13
17
16
18
19
20
22 23
24 25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
42
43
44
45
46
48
49
50
51 52
47 53
60
2
58
68
59
56
55
15 54
62
63
65
57
70
71
75
5 21
72
Double tax treaties in force (Bahrain, UAE, Qatar)
Double tax treaties pending (Kuwait, Saudi Arabia, Lebanon, Syria)
41
73 61
67
74 64 69
01. Austria 02. Azerbaijan 03. Belgium 05. Bulgaria 08. Czech Rep. 09. Denmark 10. Estonia
11. Finland 12. France 13. Germany 14. Greece 16. Hungary 17. Iceland 19. Ireland
21. Italy 24. Latvia 25. Lithuania 27. Malta 32. Netherlands 33. Norway 34. Poland
35. Portugal 36. Romania 37. Russia 38. San Marino 40. Slovakia 41. Slovenia 43. Spain
44. Sweden 45. Switzerland 49. Turkey 50. UK 52. Uzbekistan 55. Georgia 57. Moldavia
59. Cyprus 61. Albania 62. Kazakhstan 64. Kyrgyzstan 66. Liechtenstein 67. Macedonia 69. Monaco
72. Serbia 74. Armenia 75. Ukraine
04. Brazil
06. Canada
29. Mexico
47. Trinidad & Tobago
51. United States
60. Argentina
68. Barbados
20. Israel
28. Mauritius
31. Morocco
56. U.A.E.
42. South Africa
48. Tunisia
54. India
58. Bahrain
71. Qatar
63. Kuwait
65. Lebanon
70. Pakistan
73. Syria
66
No double tax treaty
Sources: LuxembourgforFinance
Tax treaty
Page 9
No tax treaty currently in force with Ukraine
Treaty voted in Luxembourg in 2001
Typical structures
• Directly or indirectly (through patrimonial vehicle)
held by a limited number of private shareholders
• Not subject to any tax in Luxembourg (only
registration duty of 0,25% of the share capital)
• No withholding tax on dividends paid without
condition
• Does not enjoy the benefits of the EU Directives
or DTTs
• Cannot grant remunarated loans
Page 11
Indiv or HoldCo
Lux SPF
Securities of any
kind
Typical Structures:
Private wealth management company (SPF) Investments in securities
Capital Dividends
Dividends,
interest, etc
• 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
• 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
Page 12
HoldCo
(DTT country)
LuxCo
EU / non-EU
Typical Structures: Holding (SOPARFI) EU or non-EU Subsidiaries
Capital
Capital
Dividends
Dividends
Typical Structures: Holding & Financing Optimization through use of hybrid Instruments
Financing Luxembourg entities
Page 13
ParentCo
LuxCo
Foreign Subs
Tracking
hybrid
loans
Capital
Dividends
Dividends
Capital
Loan
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
Debt qualification in Luxembourg if :
• (Low) Interest rate accruing even in case of
losses
• Variable interest based on profits before tax
• No stapling provision
• No entitlement to voting rights
• Preferably not convertible into shares
• 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
Financing Luxembourg entities
Page 14
Typical Structures: Hybrid instruments Debt qualification in Luxembourg
Foreign Entity
LuxCo
Hybrid
instrument Interest /
dividend
Assets Assets
Assets
Capital
Tested Hybrid Instruments (treated as debt for
Luxembourg tax purposes) :
• 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
• 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.
Financing Luxembourg entities
Page 15
Typical Structures: Hybrid instruments Debt qualification in Luxembourg
Foreign Entity
LuxCo
Hybrid
instrument Interest /
dividend
Assets Assets
Assets
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 buy-
back of instrument
- No Luxembourg WHT
• Not subject to US tax until repatriation
• Debt push down to OpCos without incurring US taxable
income Page 16
Typical Structures: Hybrid instruments Convertible Preferred Equity Certificates
ForeignCo
LuxCo
Op COs
CPEC
Capital
Dividends
Dividends
Capital
Loan
Main characteristics:
• 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
Typical Structures: Hybrid instruments Mandatory Redeemable Preference Shares
ForeignCo
LuxCo
Foreign Subs
MRPS
Capital Dividends Loan
Dividends
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)
Page 18
Typical Structures: Financing activity Intragroup financing activity – Transfer Pricing Circulars
Parent Co
LuxCo
Subsidiary
Capital
Capital
Loan
Third Party
Loan Loan
No withholding tax on interest paid by LuxCo
If orphan structure : not subject to Luxembourg TP rules
Page 19
Typical Structures: Financing activity Bonds issued through Luxembourg
Dutch Stichting
LuxCo Beneficiary
Company
Loan Bond
Interest Interest
Investors
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
Other considerations:
• 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
Other repatriation technique Repatriation through share buy-backs
ParentCo
LuxCo
Op CO
Capital
Up to 10
classes of
shares
Op CO Op CO
Op CO
Background
• Existing Company re-domiciles to
Luxembourg
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
Increase / Transfer of activities to Luxembourg Migration & Step-up in value
LuxCo ForeignCo
Foreign Subs Foreign Subs
Increase / Transfer of activities to Luxembourg Tax intangible asset amortisation
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
“business
opportunity” 100 %
Foreign
Country
Luxembourg
Group Co
LuxCo
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
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
ParentCo
LuxCo
Patent
Software
copyright
Trade
mark
Domain
name
Design &
model
IP
Luxembourg Securitization vehicle
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
Luxembourg SV
Securitised
assets
Unrestricted
investor
Hamburg 2011 - Tax Conference - Inbound Investment into Europe from North
America
Page 25
Real estate investment in Europe Through Luxembourg vehicles
ParentCo /
Investment vehicle
LuxCo
Local SPV
PPL / MRPS
/ CPEC Capital
LuxCo Lux PropCo
French SCI
/SAS
Lux PropCo
Germany UK
Interest /
dividends
France
Country X
Loan Loan Loan Loan
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
Luxembourg – a leading European real estate hub
Hamburg 2011 - Tax Conference - Inbound Investment into Europe from North
America
Page 27
Aberdeen AM
AMB
Amundi AM
Axa REIM
Aviva Investors
BlackRock CBRE
Investors
Fidelity
First State
Franklin Templeton
Goodman
Heitman Hines
ING
JP Morgan AM
LaSalle IM
MGPA
Morgan Stanley
Pacific Star
Pramerica
Prologis
Schroders
SEB AM
Tishman Speyer
UBS
(…)
Source : Luxembourg For Finance
Available investment fund structures
Regulation
UCITS
Part I UCI
Part II SIF
All type of Asset
Class
Asset Class:
limited
SICAR
SV SOPARFI
Asset Class: Strictly
limited
Flexibility
Asset Class:
VC & PE
CSSF Depositary Bank
Auditor Regulati
on & Safety
Source : Luxembourg For Finance
Hamburg 2011 - Tax Conference - Inbound Investment into Europe from North
America
Page 29
Private equity investments in Europe Through a Luxembourg SICAR, a SIF or a Soparfi
SICAR / SIF / Sop
Luxembourg SCA
LuxCo 1 LuxCo 2 LuxCo 3
NewCo
LuxCo 4
Germany Poland Country X
Bonds / convertible
bonds
NewCo NewCo NewCo
France
GP LuxCo
Investors
Advisors
Management fees
/ carried interest
Advisory
fees
Managers
Private equity investments in Europe Tax regime of Luxembourg SICAR
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
Luxembourg
SICAR
NewCo
Lux SPV
Qualified
investor
Private equity investments in Europe Luxembourg Specialized Investment Fund (SIF)
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
Page 31
Luxembourg
SIF
NewCo
Lux SPV
Qualified
investor
Loan
Luxembourg – a leading European private equity hub
Hamburg 2011 - Tax Conference - Inbound Investment into Europe from North
America
Page 32
3i
American Capital
Apax Partners
Bain Capital
BC Partners Carlyle Group
Cinven
Coller Capital
CVC
Fortress Goldman Sachs
Investcorp
JP Morgan
KKR
Kreditanstalt für Wiederaufbau
(KfW) Lazard
LGT Capital Partners
Oaktree Capital
PAI Partners
TPG Unicapital
Warburg Pincus
(…)
Source : Luxembourg For Finance
Luxembourg – a leading European “regulated”
hedge funds hub
Hamburg 2011 - Tax Conference - Inbound Investment into Europe from North
America
Page 33
Aberdeen AM
Alliance Bernstein
BlackRock
BlueBay Asset Management
Crédit Agricole
Crédit Suisse
Deutsche Bank
Fidelity
GLG
Goldman Sachs
HSBC
ING
Invesco
JP Morgan
LCF Rothschild
Lyxor
MAN
Morgan Stanley
Permal
Pioneer Investments
Transtrend
UBS
(…)
Source : Luxembourg For Finance
Hamburg 2011 - Tax Conference - Inbound Investment into Europe from North
America
Page 34
Appendix
Luxembourg investment vehicles:
comparative table
UCITS UCIs SICAR SIF SV SPF SOPARFI
Entity type SICAV (SA)
FCP
SICAV (SA)
SICAF (SA,
SCA, SARL)
FCP
Corporate (SA,
SCA, SARL,
SCOSA) or
transparent
SCS
SICAV/F
(SA, SCA,
SARL, SCOSA)
FCP
Other
(fiduciary)
Corporate
(SA, SCA,
SARL,
SCOSA)
Fund (FCP or
on a fiduciary
basis)
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
€31,000
SARL
€12,500
SA/SCA
€31,000
SARL
€12,500
SA/SCA
€31,000
SARL
€12,500
Capital (fixed /
variable) Variable
Fixed or
variable
Fixed or
variable
Fixed or
variable
Fixed for sec.
companies Fixed Fixed
Segregated sub-
funds Yes Yes Yes Yes Yes No No
Distribution of
dividends : any
restriction (except
compliance with the
min cap / NAV
requirement)
No restriction
No restriction No restriction
No restriction
(except for
interim
distributions
and for SICAF)
No restriction
for funds
(except for
corporate)
Yes Yes
Luxembourg investment vehicles
Source : Luxembourg For Finance Page 35
UCITS UCIs SICAR SIF SV SPF SOPARFI
Tax regime on
ordinary income,
capital gains, etc..
Fully exempt Fully exempt
Fully taxable
but exempt on
qualifying
securities and
transit funds
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
Is tax transparent
form available? Yes Yes Yes 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
Small annual
subscription
tax on the
NAV (0,01%
max) with
exemptions
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
Luxembourg investment vehicles
Page 36 Source : Luxembourg For Finance
Luxembourg investment vehicles
UCITS UCIs SICAR SIF SV SPF SOPARFI
Eligible investors Unrestricted Unrestricted well informed well informed Unrestricted
Individual,
private estate
management
entities or
intermediary
Unrestricted
Eligible assets /
strategies
Transferrable
securities and / or
other liquid
financial assets
Unrestricted
All types of PE / VC
(including RE PE)
and temporary
investments in
other assets
Unrestricted
Securitization
of risks linked
to any type of
assets or 1/3
party
obligations
Private
financial assets Unrestricted
Restrictions Borrowing and
high
diversification
Risk
diversification
requirements (in
principle,
investment < 20%
NAV)
Qualifying
investments
Risk
diversification
requirement
(30% NAV)
No active
management of
assets
No controlling
activity over
investments
No
Offer of securities
to investors
Subject to CSSF
approval
Subject to CSSF
approval
Subject to CSSF
approval
Subject to
CSSF approval
(with a
possibility to
launch before
approval)
Unrestricted if
non regulated
Not subject to
CSSF approval
Not subject to
CSSF approval
Pag e 37 Source : Luxembourg For Finance
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
Luxembourg investment vehicles
Page 38 Source : Luxembourg For Finance
BDO Luxembourg
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)
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
Philippe PONSARD
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.
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
Areas of
Specialization:
Corporate and
Trust Services
Domiciliation and
administration of
Luxembourg
entities
Page 42
Phone: +352 45123-357
Email:
LUXEMBOURG