Tax law in Luxembourg

• Tax structuring (investment funds formation, downstream acquisition structures, investors’ tax issues)
• Use of Luxembourg fund-type vehicles (including private equity, debt funds, real estate funds, infrastructure funds and funds of funds)
• Co-investment structuring
• Carried interest structuring
• Side letter negotiations
• Funds due diligence
• Anti-hybrid analysis
• VAT analysis

• Tax advice on corporate restructuring (M&A, demergers, liquidations, transfer of branches and joint-venture)
• Redomiciliation and migration of companies' tax residence
• Advice on bilateral and multilateral agreements on exchange of information such as FATCA/CRS and DAC 6 (EU mandatory disclosure regime) / mutual assistance and cooperation between tax authorities
• Direct, indirect taxes and duties

• Strucuturing of hybrid finance instruments, hybrid structures and different forms of partnership
• Structuring of Luxembourg securitisation vehicles and repackaging products

• Tax advice and planning for private clients, UHNW individuals and their family offices including advice on determining the suitable vehicles for the holding of private and/or professional assets - for example, private wealth companies (SPF), private funds (regulated and unregulated) or holding companies

Ogier specialises in tax audit and litigation, providing a full range of services designed to support companies and individuals through the complexities of tax law. Navigating tax audits and disputes requires a blend of precise expertise, strategic foresight, and a deep understanding of both local and international tax regulations.

Our strategy for handling tax litigation is built around the principles of proactive prevention and strategic resolution. Recognising the rapid evolution of tax laws, we emphasise the importance of dialogue and negotiation with Luxembourg tax authorities to resolve disputes in the pre-litigation phase.

This approach not only aligns with our commitment to serving our clients' best interests but also often leads to more favourable and efficient outcomes. However, when litigation is not avoidable, our clients benefit from our experience in representing them before Luxembourg's courts.

Our expertise spans a wide range of tax matters, including but not limited to corporate taxation, individual taxation and value added tax.

• Value added tax expertise
• Analysis of economic substance requirements and advice on ensuring adequate compliance and reporting