Page 246 - Invited Paper Session (IPS) - Volume 1

IPS152 Paul F.
continue in the next few years . Second, US MNEs withdraw capital from
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Luxembourg further to the 2017 US tax reform.

logy of Luxembourg SPEs
Total 3.1 - 3.2 - pure 3.3 - 3.4 - loan
Label and functional conduits holdings intragroup origination
category (for RoW part) lending
2016 2018 2016 2018 2016 2018 2016 2018 2016 2018
Total assets 9 599 8 577 891 696 3 415 2 707 5 204 5 096 90 78
Debt securities held PI 321 397 131 177 2 3 170 198 18 18

Participating DI 6 819 6 152 342 221 3 283 2 616 3 167 3 293 27 22
interests
Loans to affiliates* DI** 2 276 1 846 380 278 120 86 1 736 1 450 40 32
Other assets DI 183 182 38 20 10 1 131 155 5 5
Total liabilities 9 600 8 577 891 696 3 415 2 707 5 204 5 096 90 78

Debt securities PI 1 115 973 720 515 16 17 360 419 19 21
issued
Capital DI 5 831 5 167 86 94 3 181 2 427 2 551 2 632 12 13
Loans from DI 2 510 2 209 63 85 217 182 2 184 1 905 47 36
affiliates
Other liabilities OI 144 228 22 1 1 80 109 140 12 7
* to non affiliates for 3.4
** OI for 3.4
Source: BCL, Billions €

3.1 Entities issuing debt securities (other than securitization vehicles)
Those entities are further broken down into two subgroups:
- Some companies issue debt securities on open markets and lend the
proceeds inside the group.
- Some other companies issue more sophisticated instruments (e.g.
certificates), classified as debt securities, not necessarily on open markets.
This model has been declining since 2017.

3.2 Pure holdings
Some other entities have a basic wealth management structure, i.e. issue
capital and hold participating interests. This model has been declining since
2017 as well.

3.3 Entities performing intragroup lending
More diversified entities also take and grant loans inside the group. Debt
instruments, overall loans, are classified Direct Investment. The model has
remained stable since 2016.

BEPS does not directly touch upon the most significant part of Luxembourg financial industry,
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i.e. deposit-taking corporations, Money Market Funds, Investment funds, Securitization Vehicles
or Insurance Corporations.
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