7 October 2022 | 6 min read
The interest free loan: a financial instrument prone to recharacterisation by the Luxembourg judge?

Aurélie Clementz
Deal
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With almost 20 years of practice, Aurélie has significant expertise in advising clients on international investment funds tax structuring via Luxembourg regulated and non-regulated vehicles, with a specific focus on infrastructure, debt, private equity and real estate. She also specialises on the tax aspects of co-investment and private equity structuring, investment side letter negotiations and funds due diligence and has a strong anti-hybrid expertise.
Aside from her focus on investments funds and financial investors, Aurélie has significant experience in cross-border transactions, including restructuring, refinancing, and tax planning for multinational groups and private equity sponsors.
Aurélie's objective is to simplify complex tax issues for clients and to provide efficient tax structuring and solutions that meet clients' commercial objectives.
Before joining Ogier in 2023, Aurélie was a tax counsel for another leading law firm in Luxembourg. She graduated from the Paris I (Panthéon-Sorbonne) and Paris II (Panthéon-Assas) Universities and is a French-qualified (Paris Bar) and a Luxembourg-qualified lawyer (Liste IV).
Aurélie started her career in Paris, where she worked for English law firms for eight years. She then moved to a leading international law firm in Luxembourg in 2011. She has also worked from London and Beirut.
Aurélie is a member of tax-related working groups of the Luxembourg fund industry association (ALFI) and is also a member of the Ladies in Law Luxembourg Association (LILLA).
Admitted in:
2011 - Luxembourg
2003 - France
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7 October 2022 | 6 min read
The interest free loan: a financial instrument prone to recharacterisation by the Luxembourg judge?
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