North Star Corporate Finance has successfully completed the restructuring of the French real estate holding structure for a pan-European Real Estate Fund, including the introduction of an OPCI within the group structure.
The restructuring, led by the team at North Star, involved layers of legal, tax and regulatory complexity, in particular noting the existing real estate which was required to be transitioned into a tax transparent structure and the overall holding structure was itself part of a wider open-ended investment company domiciled in Luxembourg. The implementation required substantial technical dexterity together with operational aspects with the appointment and directing of the local French portfolio management company and depositary. The OPCI was approved by the AMF, the local regulator.
The purpose of an OPCI (“Organisme de Placement Collectif Immobilier”) is to primarily invest in French real estate assets for rental activity or to build assets exclusively for lease, either directly or indirectly. The primary benefit being, assuming certain tests are met, the structure provides French tax transparency for the purpose of income and gains arising from the real estate.
Managing Director, Andrew Månsson-Lowe, commented “Whilst OPCIs are traditionally open-ended pooled investment vehicles for real estate, in response to the shifting fiscal landscape in Europe with the implementation of BEPS and other changes such as the double tax treaty between Luxembourg and France, professional OPCIs are being increasingly utilised to optimise the efficiency of intra group structures. Whilst a challenging transaction, we are delighted to have successfully delivered the project for our client to meet their commercial objectives.”
About North Star Corporate Finance: North Star offers technical corporate finance expertise with overall project delivery to funds and fund managers in the UK and across Europe. Our expertise includes structuring and restructuring real estate funds into OPCIs, PAIFs and REITs both onshore and cross-border. For more information about North Star Corporate Finance and how we can assist please get in touch.
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