Investing in the EU through an SPV

International Tax Review is part of Legal Benchmarking Limited, 1-2 Paris Garden, London, SE1 8ND

Copyright © Legal Benchmarking Limited and its affiliated companies 2026

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement

Investing in the EU through an SPV

To route their investments in a tax efficient manner, investors in the EU often use special purpose vehicles (SPV) incorporated in a third-party jurisdiction. The preferred jurisdictions are generally Luxembourg, the Netherlands, and, to a lesser extent, the UK or Switzerland (which benefits from certain EU directive rules under EU-Swiss agreements). Antoine Vergnat of McDermott Will & Emery in Paris provides a practical description of the main substance-related requirements that SPVs must satisfy to benefit from exemptions or reductions of withholding taxes on portfolio incomes derived from EU operating companies (which assets are not predominantly made up of real estate assets).

Unlock this content.

The content you are trying to view is exclusive to our subscribers.

To unlock this content:

Take a Free Trial or Login
more across site & shared bottom lb ros

More from across our site

In the first of a two-part series, experts from Khaitan & Co dissect a highly anticipated Indian Supreme Court ruling that marks a decisive shift in India’s international tax jurisprudence
The OECD profile signals Brazil is no longer a jurisdiction where TP can be treated as a mechanical compliance exercise, one expert suggests, though another highlights “significant concerns”
Libya’s often-overlooked stamp duty can halt payments and freeze contracts, making this quiet tax a decisive hurdle for foreign investors to clear, writes Salaheddin El Busefi
Eugena Cerny shares hard-earned lessons from tax automation projects and explains how to navigate internal roadblocks and miscommunications
The Clifford Chance and Hyatt cases collectively confirm a fundamental principle of international tax law: permanent establishment is a concept based on physical and territorial presence
Australian government minister Andrew Leigh reflects on the fallout of the scandal three years on and looks ahead to regulatory changes
The US president’s threats expose how one superpower can subjugate other countries using tariffs as an economic weapon
The US president has softened his stance on tariffs over Greenland; in other news, a partner from Osborne Clarke has won a High Court appeal against the Solicitors Regulation Authority
Emmanuel Manda tells ITR about early morning boxing, working on Zambia’s only refinery, and what makes tax cool
Hany Elnaggar examines how AI is reshaping tax administration across the Gulf Cooperation Council, transforming the taxpayer experience from periodic reporting to continuous compliance
Gift this article