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Visual Structures

Luxembourg AIF Fund & Financing Structures

Detailed visual diagrams showing how the fund structure works and how financing can be arranged at different levels.

Fund Structure Overview

This diagram shows the ownership chain from the client down to the German income-producing buildings. The Luxembourg AIF sits between the client and the German property SPVs, providing flexibility for exits, partner entry, and institutional appeal.

Client / Family Owner

Holds fund units

Ownership

Luxembourg AIF

(SCSp / RAIF)

Tax neutral at fund levelRegulated structureInstitutional appeal
Holds shares

German Property SPV

(GmbH)

Holds German real estateGerman tax treatment
Owns

Income-Producing Buildings

Located in Germany

Rental incomeCapital appreciation

Key Points

  • In practice, there can be multiple German SPVs under the same Luxembourg fund, each holding different properties
  • German rental income is still taxed in Germany at the SPV level
  • The value of this structure is in liquidity, transfer efficiency, and institutional investor appeal