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

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
As tax authorities embrace AI and governments weigh pillar two reforms, Latin America is developing a more connected and internationally focused tax agenda
Advisers with pre-existing corporation tax or self-assessment accounts must now register or risk enforcement action from HMRC
India's tax authorities are increasingly scrutinising the rationale behind cross-border structures
Sharmila Sanmugam's move from industry to WTS UK offers an early glimpse into how the fledgling firm hopes to compete with larger rivals
Historical claims involving KPMG Australia's tax practice have surfaced as the firm battles a separate parliamentary inquiry into its handling of whistleblowers
Gift this article