Denis-Emmanuel Philippe has developed a particular expertise in relation to certain Luxembourg investment vehicles (SOPARFI, SICAR, SCSp, SICAV, RAIF, SCI, etc.), for which he has published a reference book in the form of a guide for Belgian tax residents who wish to invest in these structures.

He is thus very familiar with the complex Belgian tax issues related to these structures (Cayman tax, tax on savings (19bis), tax transparency, dividend remittance (Belgian regime for definitively taxed income), tax on stock exchange transactions, tax on securities accounts, etc.), but also with Luxembourg taxation (Luxembourg IS, Luxembourg RDT condition, etc.). He can therefore advise his clients on both Belgian and Luxembourg tax aspects.

Denis-Emmanuel Philippe also regularly submits tax rulings to the Service des Décisions Anticipées (SDA) on behalf of his clients to provide legal certainty for their investments in the above-mentioned Luxembourg structures, but also in French structures (SCI) or Dutch structures (fonds voor gemene rekening).

In addition, he regularly assists his clients in tax audits in relation to these foreign structures, which may involve very complex issues (Cayman tax, tax on savings, taxation of capital gains on the sale of SCI shares, application of double taxation treaties, application of the general anti-abuse provision (article 344)).

 

 

News

Topics

Contact