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:

Request Access or Login
more across site & shared bottom lb ros

More from across our site

A landmark ruling on LLP taxation has clarified who truly holds ‘significant influence’ and which partnership structures are most likely to withstand HMRC scrutiny
Chris Jordan promoted tax schemes to clients and received illicit payments, it has also been alleged
Solving the UK's fiscal deficit requires an ‘ease of doing taxes’ framework driven by tax-as-code – not thousands of additional auditors
Despite the ongoing audit controversy, the firm’s tax and legal division saw revenue growth of 10.9%
Fresh from the UN negotiations in New York, Alex Cobham offers ITR readers a rare first-hand perspective on the future of international tax cooperation
Around 450 client-facing roles are due to be axed next week, it has been reported
The OECD may be making a mistake if a 2029 review is intended to outlast Trump in the hope of more favourable treatment from the US Democrats
Nexdigm has invested in Singapore-based infer360, a TP intelligence product designed by ex-PwC partners
Awards
ITR is delighted to reveal all the shortlisted nominees for the 2026 Americas Tax Awards
Despite initial hopes that the reporting obligation had been suspended, compliance challenges brought by Brazil’s indirect tax reform are very much a reality
Gift this article