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Direct Tax
Trophy assets are evolving from personal indulgences to structured investments, prompting family offices to prioritise tax efficiency, governance discipline, and cross-border compliance
May 21, 2026
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  • Steve Mendelsohn, managing director of Knowledge Solutions for the Tax & Accounting business of Thomson Reuters, looks at how the technology revolution is helping corporate tax professionals access better organised and more structured information for informed decision making.
  • Cédric Tussiot and Joachim Bailly look at intermediation in the sale of shares of real estate companies in Luxembourg and whether VAT should be applied, based on the recent European Court of Justice case for broker firm DTZ Zadelhoff vof.
  • 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).

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