June 15, 2022
Since the start of her career, Marie has had numerous expatriate assignments. With Jean, her former husband, she has lived and worked in several different countries. Together they have two children, Jacques and Manon. After their divorce, Jean returned to France with the children to provide them with a stable educational environment. For her part, Marie continued her career abroad. She takes advantage of all free periods to return to France in order to see her children. They frequently spend their school holidays with her and have already experienced life in many different countries. Jacques is now a young and talented professional and has worked for 2 years at the Paris head office of a multinational. Manon is completing her studies this year and is preparing to start her career as a researcher. They both intend to stay in France, close to their roots.
Currently working in the Middle East, Marie is preparing to leave the region for a country in Asia, where she is scheduled to stay for at least 5 years. She is planning to return to France some time in the future.
- Constitute and secure a portfolio of movable assets in a context of international expatriation
- Entrust the management of the assets to a specialist management company
- Prepare for the transfer of the assets by means of a flexible, portable and fiscally secure solution
The OneLife solution
For a flexible international solution, Marie’s advisor knows that the Luxembourg life assurance policy is the most appropriate vehicle: security of the invested assets and tax neutrality lay at the heart of the Luxembourg offering. He therefore calls on support from the experts at OneLife to design a bespoke solution for Marie.
The OneLife advisors propose a Luxembourg life assurance policy with the following characteristics:
- Marie will be the policyholder, it is her life that will be insured
- Jacques and Manon are the beneficiaries of the policy
- The assets dedicated to the policy will be invested in an internal dedicated fund (IDF). This vehicle enables Marie to engage the services of an authorised management company, which will establish her profile and investment strategy and will subsequently be responsible for managing the portfolio
- The policy’s assets will be entrusted to a custodian based in Luxembourg and will enjoy maximum protection under Luxembourg legislation
Meeting the objectives
From a wealth management point of view
- The discretionary management IDF enables Marie to entrust the management of her assets to a professional with a clear mandate in line with her profile and objectives. The asset manager will have access to a wide range of investment options (investment funds, trackers, listed equities, unlisted equities, bonds, forex, etc.) within the limits of its mandate and in compliance with Luxembourg legislation.
- Marie will be able to retain her policy once she has relocated to Asia, and also in the event of any future expatriate assignments and her return to France.
- Marie will be able to place additional funds in her policy in the future. The digital solutions offered by OneLife will enable her to quickly and remotely manage the details with the assistance of her advisor.
From a tax point of view
During the lifetime of the policy
Thanks to the tax neutrality of Luxembourg, the tax treatment of the various transactions (payment of premiums, redemptions) will solely depend on Marie’s country of residence. Depending on the country of the issuer of the assurance policy’s underlying assets, in addition to the type of assets, withholding may apply when interest and/or dividends are paid in each asset’s country of origin. This will then be reflected in the value of the fund and will be borne by the policyholder via the assurance policy.
On settlement of the policy.
- The solution is tax neutral as far as Luxembourg is concerned. Tax treatment will depend on Marie’s country of residence at the time of her decease.
- If Jacques and Manon are still tax resident in France at the time of decease, French taxation will apply to them. The advantageous tax regime of the life assurance policy enables each child who is a tax resident in France to enjoy an allowance of EUR 152,500 and a fixed rate in excess of this amount.
Thanks to the support received from OneLife, Marie’s advisor was able to find a bespoke solution that fully meets her objectives. In the event of further expatriation after Asia, the experts at OneLife will be able to analyse the legal and tax consequences of the new place of residence and adapt the policy accordingly. The same applies in the (unlikely) scenario of the children becoming expatriates. Marie therefore has a flexible and adaptable solution.
Want to know more?
Discover in our whitepaper the benefits of Luxembourg life assurance and its application through some practical cases.
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