We have been mandated by an international group for transferring its industrial and commercial shareholdings towards a Luxembourg Société en Commandite Simple that holds and consolidates the holding of those industrial and commercial shareholdings.
The client holds participations into subsidiaries established in the Middle-East, Africa and in Central Eastern Europe.
SCS was considered as the vehicle that will allow the client to keep the broadest flexibility over time and the long lasting with view to the current group structure and the tax developments in Luxembourg and at international level.
SCS has the main benefit of being in principle tax transparent and income distributed are not subject to the 15% Luxembourg dividend withholding tax.
SCS 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 SCS is not constitutive of a permanent establishment of its partners in Luxembourg and as long as SCS is not considered as having a commercial activity.
