Paris tax head Thomas Perrot spoke at the 17th annual "Tax Planning Strategies — U.S. and Europe" conference in Barcelona on April 5. The event organizers included the American Bar Association Section of Taxation. Mr. Perrot gave an overview of the ways that cross-border real estate investments should be structured for both taxable and tax-exempt funds, with an emphasis on (1) direct investment in real estate versus an investment in a real estate company, (2) minimizing withholding tax (or getting a refund of taxes that must be withheld) and the use of an EU intermediate holding company ‎in this context given the anti-abuse provisions introduced in the EU Parent-Subsidiary Directive, (3) restrictions on the deduction of interest and the impact of the EU Anti-Tax Avoidance Directive, (4) reducing or eliminating VAT and/or real estate transfer tax liability, and (5) reducing or eliminating capital gains taxation.
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