This article will discuss structuring considerations at Luxembourg fund level. The following questions will be answered:
- Why Would a USCFM Need a Luxembourg Fund Vehicle to Onboard EU Investors?
- Is a Luxembourg Fund Vehicle Needed to Get Access to Certain Pools of EU Borrowers?
- Is a Luxembourg Direct Lending Fund Regulated As a “Professional Lender” under Luxembourg’s Banking Laws?
- What Is the Typical Legal Form of a Luxembourg Credit Fund?
- What About Investor Confidentiality?
- Should the SCSp Adopt the RAIF Regime?
- How Is the Luxembourg SCSp Taxed?
7.1 Municipal Business Tax: Is There an Actual or a Deemed Business?
7.2 Reverse Hybrid Rules - Must an SCSp Have a Luxembourg GP?
- What Is the Luxembourg Footprint Needed to Secure the Central Administration in Luxembourg?
- How To Design the Management Fee Flow (Commercial and Tax Considerations)?
- How to Design the Carried Interest?
- Raising Capital: Is There Still Room for Reverse Solicitation in the European Union?
- Testing Appetite with EU Prospective Investors: How to Do It?
- There Is Investor Appetite: What Is the Timing for the Fund Launch?
- Launching with or without an EU Host AIFM?
- Host AIFM Model: Interactions Among the USCFM, the Host AIFM and the Depositary
- What Is the Typical Design of the Entity That Faces EU Borrowers?
- How Is the Luxembourg Borrower-Facing Entity Financed?
- Managing Currency Exposure and Luxembourg Tax Leakage on Currency Results
19.1 Currency Exposure Mitigated by Currency Hedges
19.2 At Which Level in the Fund Structure Should the Currency Hedges Be Concluded?
19.3 Tax Exposure on Currency Results
19.4 Functional Currency Tax Reporting
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