By Antoine DUPUIS and Thibaut BOULANGÉ, ATOZ Tax Advisers*
Since the GFC, private credit as an asset class has benefited from a conjunction of multiple factors from stricter regulatory rules for banks to investors’ quest for yield. It has grown significantly in the US and in Europe and has attracted huge flows of capital over the last years. Traditionally, the UK has been one of the hottest markets in Europe for private credit, which fund managers have invested billions of GBP into, despite the looming threat of Brexit. Pan-European as well as UK-centric credit funds have often been established in Luxembourg as investment platforms, holding diversified pools of credits and relying on well-known and understood operational structures.
One of...
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