Does the change in the French-Luxembourg Tax Treaty bring an end to tax efficient real estate structuring in France?
The answer is NO.
Actual situationThe actual French-Luxembourg tax treaty is an old treaty which contains a favourable capital gain taxation article. As a result most French real estate acquisitions are structured in the way whereby the French real estate is acquired by a French company which is owned by a Luxembourg holding company. The disposal of the French real estate entity by the Luxembourg holding company is exempt from French and Luxembourg capital gain tax.
Amendment of the French-Luxembourg Tax TreatyThe French and Luxembourg governments have signed a new amendment to the tax treaty that will significantly...
The Malta Citizenship by Investment Programme is the first of its kind to get EU approval. The Programme grants rights of full citizenship for life, including analogous access to all investment and employment opportunities available throughout the EU to Maltese and EU citizens.
Gerard Jan van Spall, Commercial Director, Vistra Malta provides an overview of the Programme in the attached article, which appears in Issue 252, January 2015 of Offshore Investment Magazine.
Vistra Group today announces the launch of a refreshed brand that unites Vistra and OIL, the group’s main internationally operated brands under the same family. The new brand heralds an exciting new chapter in the Group’s strategic development and culminates four years of successful integration and formalises the connections that all the member companies share.Under the new brand, Vistra and OIL remain as distinct and complementary brands operating separately but with a strong linkage between them symbolising the integrated way in which the group operates. Additional brands joining the Group as a result of various acquisitions will also follow the new brand hierarchy depending on their market position.Following the acquisition of Trinity...
Vistra today announced the acquisition of Fiduciary Management Limited ("FML"), an independent trust company business based in Jersey.
Since its establishment in 1996, FML has maintained its focus as a high quality provider of trust and corporate services to high net worth private clients and international companies, with an emphasis on a personal, professional and flexible service. Paul Le Marquand and Lynda Vautier, the principals of FML, supported by their team of professionals, will join Vistra and play a key role in the management of client services and the ongoing development of the business. The acquisition will bring Vistra's staff numbers in Jersey to 75.
Since the Individual Investor Programme (IIP) was set up in November 2013, 'Identity Malta'; the authority set up by the Government to oversee the programme, has received around 300 applications for citizenship. Identity Malta has confirmed that a number of citizenship applications have now been approved, with those particular applicants having already been resident in Malta for one year.
The one year residency clause, meaning that citizenship in Malta can only be granted after 12 months, has been an important addition to the IIP. During these 12 months, applicants will need to be present in Malta for a set period of time (but not necessarily 365 days).
Applicants will also be required to provide evidence of a genuine link with Malta....