Deals & Cases
Transparency for Swiss tax purposes of Luxembourg investment fund in the form of a société en commandite par actions
A large Luxembourg investment fund providing mezzanine financing to Swiss corporate borrowers faced the risk of incurring withholding tax for interest on mortgage loans.
In December 2019, Meyerlustenberger Lachenal Ltd. negotiated a ruling which applied the tax rules for Swiss limited partnerships for collective investment to a Luxembourg société en commandite par actions, thereby ensuring tax transparency of that entity and treaty benefits for the investors.
The successful negotiations were led by Thomas Nabholz (Partner, Head Tax Practice).
