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.
A new focus on early intervention and increased AI use is transforming how tax authorities are approaching TP audits, though capacity-constrained jurisdictions risk falling behind
The French administration has used AI to detect undeclared swimming pools and verandas but always includes a human in the loop, the AI in Tax Forum heard
India’s Supreme Court rattled cross‑border structuring with its Tiger Global ruling. Subsequent rule changes narrowed the impact, but significant risks around GAAR, substance and treaty access persist
ITR sat down for a pre-event interview with Tim Zech, WTS Germany, and Jeff Soar, WTS UK, keynote speaker at next week’s ITR AI in Tax Forum 2026 in London
April 22 2026
Gift this article
As a premium subscriber, you can gift this article for free
https://www.demo.com/demo-article/
Link copied to clipboard
You have reached the limit for gifting for this month
There was an error processing the request. Please try again later.