One of our clients, tax resident in another continent, wanted to develop more its anchor in Luxembourg through organizing its personal wealth management through a Luxembourg Société en Commandite Spéciale (SCSp).
In a 1rst instance, SCSp was used as a regional investment platform.
SCSp is financed only through equity or also from advance from the client.
The foreign individual is the Limited Partner of SCSp and the General Partner is a Luxembourg Sàrl, also held by the individual.
SCSp is a flexible family governance tool that allows private wealth management together with succession planning opportunities (distinction between bare-ownership and usufruct).
SCSp should not be subject in principle 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 is not constitutive of a permanent establishment of its partners in Luxembourg and as long as SCSp does not go beyond a private wealth management.
