Amicorp Corporate Management Corporate
Management
A division of the Amicorp Group
 
 
 
 
 
         
 
 
     
     
   
     
 
 
 
 
     
 
 
 
 
 
   
   
   
 
 
Preferred Equity Certificates (PECs)
 
In order to optimize financial flows, interest expenses should preferably be tax deductible, and an accrual or recognition of interest income should, preferably, occur at a later time. Combining Luxembourg's accounting and tax rules, a debt instrument can be created that works in connection with an US resident lending to a Luxembourg company.
 
Benefits:
  • Can be used to purchase subsidiaries, loans, real estate and other assets
  • Avoids the recognition of taxable income for US creditor
  • Provides immediate interest deductions in Luxembourg
  • Interest deductions can be used to offset Luxembourg taxable income
  • Interest is not subject to withholding tax in Luxembourg
  • Avoids Luxembourg net worth taxation (upon 'unitary value' of companies or branchesvested in Luxembourg)
 
For more information
 
  Company formation  
  Director and Nominee Services  
  Corporate Administration Services  
  Private and Public Fund Structures and Administrative Services  
  Royalty Management Services  
  PEC's  
 
   
   
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