The Client

Commercial jet leasing company

 

The Problem

Our client wanted to acquire a jet and lease it commercially in Latin America, repatriating the profits in their LATAM jurisdiction. They asked us to help structure the transaction efficiently.
 

The Solution

Our proposed structure required the owner of the aircraft to contribute to an EU incorporated company in return for a jouissance right for up to 95% of the profit.
While leasing income was liable to 25% corporation tax in the EU jurisdiction, the jouissance right (structured as a debt instrument) allowed the interest payable to be tax deductible leaving a nominal amount subject to tax.
Our client’s interest was not taxable on repatriation under the relevant double tax treaty.