Professionals in the credit sector established a Private Debt fund in Luxembourg under the form of the Société en Commandite Spéciale (SCSp).
SCSp Fund provides secured financing to alternative lenders.
Besides SCSp Fund where institutional investors will invest, another SCSp Feeder for high net wealth individuals investing in SCSp Fund was created.
The General Partner of SCSp and SCSp Feeeder is a Luxembourg Société à Responsabilité Limitée.
SCSp Fund benefits from the Reserved Alternative Investment Fund regime under the law of July 23, 2016 whereas SCSp Feeder will benefit from the Law of July 12, 2013.
SCSp Fund as RAIF is only subject to the annual 0.01% subscription tax levied on the net asset value of the fund, calculated on the last day of each quarter, and is not subject to Luxembourg corporate and municipal business tax nor net wealth tax.
SCSp Feeder should not be subject to the Luxembourg corporate income tax of 17%, to the municipal business tax of 6,75% in Luxembourg city and to the 0,5% net wealth tax, assuming SCSp Feeder is not constitutive of a permanent establishment of its partners in Luxembourg and as long as SCSp Feeder is not considered as having a commercial activity because considered as an alternative investment fund according to the Law of July 12, 2013.
Luxembourg Société à Responsabilité Limitée receives management and performance fees on the assets under management.
