Luxembourg/Jersey

[Luxman199]

Hello,

I have a trust in Jersey and an operating company in Luxembourg. Do you know any legal strategy possible to be used to upstream funds from a very efficient manner ? I was thinking about CPECS or PEC but I am unsure if using an hybrid instrument could help.

Thank you all

 

[uplana]

Where do you live actually?

 

[Luxman199]

Where do you live actually?

Hello - I am resident in Jersey

 

[Lateraltrust]

Hello,

I have a trust in Jersey and an operating company in Luxembourg. Do you know any legal strategy possible to be used to upstream funds from a very efficient manner ? I was thinking about CPECS or PEC but I am unsure if using an hybrid instrument could help.

Thank you all

Yes absolutely, you can redeem a part of your capital . This will be materialized by the buying back and cancelation of the company own's shares. You will absorb the corresponding portion of profit to Jersey free of withholding tax. This was confirmed by caselaw un november 2017.

Hybrids are no longer efficient due to the full implementation of ATAD in luxembourg (except in rare cases). But there is no need to use an Hybrid in your case