Our practices
Tax
We advise on Luxembourg and cross-border tax – combining technical depth with a strong transactional focus.
Our Tax practice sits at the core of our integrated business-law offering.
We advise investment funds, corporates, family offices, and ultra-high-net-worth individuals on the tax dimensions of their transactions, investments, and structures, with a particular focus on cross-border and multi-jurisdictional matters. Our work spans transaction tax and acquisition structuring, holding and financing arrangements, fund and investor-level taxation, management incentives and carried interest, transfer pricing considerations, and tax efficiency in wealth and succession planning. We also advise on the practical implications of the evolving international framework – Pillar Two, ATAD 1 and 2, DAC6, and substance and beneficial ownership requirements – and assist clients in obtaining advance tax clearances and managing relationships with the Luxembourg tax authorities.
Rather than operating as a standalone technical function, our tax expertise is embedded into the deal process from the outset. This allows us to identify exposure early, optimise structure before it is locked in, and design solutions that are both technically sound and commercially effective, in close coordination with our Corporate, Banking & Finance, Investment Funds & Private Wealth, and, where relevant, Dispute Resolution teams throughout.
We focus on clarity, pragmatism, and preserving strategic flexibility across the full lifecycle of a transaction or structure.
Areas of focus
Corporate & International Tax
Advising on Luxembourg and cross-border tax structuring for multinational groups and investment platforms.
- Holding & Financing Structures
- ATAD 1 & 2
- Pillar Two / GloBE
- Substance & Beneficial Ownership
- Tax Treaties
Transactional Tax
Tax structuring and due diligence across the full deal lifecycle, from acquisition to exit.
- M&A & Private Equity
- Real Estate
- Securitisation & CLOs
- Debt Restructuring
- Financing Transactions
Funds & Asset Management
Tax-efficient fund structuring for sponsors, managers and investors.
- Fund Structuring
- Carried Interest & Management Incentives
- Investor Tax Structuring
- Subscription Tax
Private Clients & Wealth
Personal tax planning for entrepreneurs, executives and high-net-worth families.
- Relocation & Impatriate Regime
- Wealth & Estate Structuring
- Personal Income Tax
- Life Insurance Taxation
Indirect Tax
VAT and transfer taxes across corporate, fund and real estate transactions.
- VAT
- Registration Duties
Tax Controversy, Compliance & Reporting
Defending taxpayers before the Luxembourg tax authorities and courts, and managing reporting obligations.
- Audits & Tax Litigation
- Mutual Agreement Procedures & Arbitration
- DAC6
- FATCA / CRS
- Rulings
Tax that closes the deal.
Swale & Spark – Tax
Who we work with
- Multinational Groups
- Institutional Investors
- Asset Managers
- Banks and Credit Institutions
- Insurance and Reinsurance Undertakings
- Family Offices and UHNWI
Practice partner
Pierrick Romancant
Tax
View profile →