Tax

Where local tax is an important consideration in an international transaction, Ogier's Tax team draws together partners with specific tax expertise from each of our locations to support financial institutions, multinational corporates, funds and asset managers.

Our partner-led teams also advise on regulatory tax matters and on new economic substance legislation, supporting clients on the nuances in substance laws across the offshore world and on reviews of complex, multi-jurisdictional offshore structures within the context of economic substance requirements.

You can read more at our dedicated substance page here.

Advising on offshore and Luxembourg structures, we work hand in hand with tax departments at onshore law and accountancy firms on all aspects of cross-border advisory and transactional tax matters, including cross jurisdictional analysis as to which of our jurisdictions is most appropriate for a client's specific commercial and regulatory needs.

In each case we offer practical experience of how issues of management and control on tax residence are addressed in each of our jurisdictions.

Services

Services

  

  • Analysis of economic substance requirements and advice on ensuring adequate compliance and reporting
  • Direct and indirect taxes and duties in each location
  • Local property taxes, consumption taxes and other "tax like" charges
  • Obtaining Luxembourg income tax clearance
  • Advice to businesses wishing to establish an entity in our locations (including cross jurisdictional analysis as to which of our jurisdictions is most appropriate for a given business)
  • Tax advice on corporate restructuring such as mergers and acquisitions, scissions, liquidations, transfer of branches
  • Redomiciliation and migration of trusts and tax residence of companies
  • Advice related to bilateral and multilateral agreements on exchange of information and international conventions regarding mutual assistance and cooperation between tax authorities
  • Guernsey tax exempt status for investment funds
  • Tax issues concerning private wealth including advice in respect of trusts, companies and foundations as vehicles for the holding of private wealth and consideration of the taxation implications of changing control dynamics of those vehicles
  • The quoted Eurobond exemption and associated listing services on Cayman and Channel Islands stock exchanges
  • Transfers of assets within the jurisdiction related to aircraft and other high value movable assets
  • Use of hybrid finance instruments, hybrid structures and different forms of partnership
  • Use of Luxembourg fund-type vehicles
  • Use of securitisation vehicles