The taxation of the foreign trusts in Luxembourg will depend on their treatment either as an independent estate (distinct legal entity that is subject to independent taxation) or as a fiduciary agreement (i.e. tax transparent – tax impact arises directly in the hands of the beneficiaries) for tax purposes. Usually only irrevocable discretionary trust can be considered independent estate. Partially discretional trusts like the Existing Trusts will likely be considered as tax transparent fiduciary agreements.

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Далее еще имеется вот что (не в моей части перевода):

A patrimoine d’affectation may be defined as an economically independent estate, segregated from the other assets and liabilities of the founder’s estate, affected to a specific purpose and which may not be taxed in the hands of another taxpayer.

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As a general rule, it should be noted that only an irrevocable discretionary trust can usually be considered as an independent estate for Luxembourg tax purposes. However risks related to the tax residency of such an estate and a potential PE establishment in Luxembourg depending on the assets of the trust and management bodies including persons exercising “negative control” rights should be carefully assessed.

Независимая собственность?

Спасибо.