Real Estate
For most of the families we advise, real estate represents a substantial share of total wealth. It is often the oldest asset, the most visible and the most emotionally charged. Paradoxically, it is also the least well managed from a wealth planning perspective.
Many of our clients come to us with a property portfolio built up over years and generations, with no overarching strategy: inherited properties in one country, others acquired opportunistically in another, some held directly, others through structures set up in haste — a French SCI here, a Luxembourg Sàrl there, an Italian società semplice elsewhere — with financing that has matured and rental yields rarely compared to what the tied-up capital could generate in financial markets. The result is too often a concentrated, illiquid, tax-inefficient estate that is difficult to pass on.
At Belisama, we approach real estate as a component of overall wealth, not as a separate universe. Our role is not to sell you properties or to encourage you to buy. It is to help you answer the fundamental question: does your property portfolio serve your life plan, or is it the other way around?
A comprehensive approach
We operate across the full spectrum of wealth-related real estate, with a particular focus on cross-border situations involving France, Luxembourg, Italy, Belgium, and Switzerland. Strategic diagnosis first: mapping all properties across jurisdictions, analysing concentration by geography and currency, assessing true yield net of local taxation, charges and vacancy, and identifying which assets to retain and which to divest. Structuring next: selecting the right vehicle in the right jurisdiction, coordinating tax treaty provisions, and ensuring that the overall architecture is both compliant and efficient. Execution last: we coordinate a rigorously selected network of partners for acquisitions, disposals, refurbishment and property management in each market.
Your property portfolio deserves the same analytical rigour as your financial portfolio. More often than not, that is where the greatest optimisation potential lies — especially when holdings span multiple jurisdictions.
Property wealth strategy
Owning a large property portfolio does not mean owning a well-managed one. The distinction is fundamental, and it is often where our work begins.
A sound cross-border property estate meets four criteria: it is diversified (across geographies, property types and ownership structures), it is liquid (or its liquidity is organised for when it is needed), it is tax-efficient (the right vehicle, the right regime, the right holding period in each jurisdiction), and it is transferable (without succession friction, without a punitive tax event, without conflict between heirs subject to different national laws).
Most of the property portfolios we review fail to meet all four. Concentration is the most common problem: the bulk of the estate in two or three properties, often in the same city, often held directly, often acquired on terms that bear no relation to the current market. The second problem is unplanned illiquidity: the wealth is there on paper, but mobilising €500,000 within three months to seize an opportunity or cover an unexpected need is an uphill battle, particularly when assets are locked in structures across different legal systems.
We build property wealth strategies around three questions. What to keep? Properties with strong emotional value, properties with a real yield above the opportunity cost, properties that play a role in the succession strategy across the relevant jurisdictions. What to divest? Dispose of properties whose continued ownership is no longer justified, reinvesting the proceeds into more liquid, more diversified or higher-performing assets. How to restructure? Select the appropriate vehicle in each jurisdiction, coordinate cross-border tax treatment, and use financing tools to unlock liquidity without triggering unnecessary capital gains.
Every recommendation is documented, quantified and integrated into the overall wealth strategy. Real estate is not treated in isolation: it interacts with the financial portfolio, tax planning, succession and the life plan.
Restructuring a cross-border property estate
Restructuring a property estate means moving from historical accumulation to deliberate architecture. It means replacing chance with intention, and inertia with strategy. For families with holdings across multiple jurisdictions, the complexity is compounded by differing legal systems, tax treaties and succession rules, but so is the optimisation potential.
The tools available for property restructuring are numerous, but their effective use depends entirely on your personal circumstances: age, tax residence, nature and location of the properties, existence of heirs in different jurisdictions, disposal plans, liquidity needs and risk tolerance. There is no one-size-fits-all solution, only tailored combinations.
The SPF (Société de gestion de Patrimoine Familial)
A Luxembourg vehicle specifically designed for private wealth management. The SPF is exempt from corporate income tax, municipal business tax and net wealth tax on its income from financial assets, participations and cash. It may not engage in commercial activity and its shares must be held by individuals, family trusts or wealth management entities. For families seeking a tax-neutral holding layer for financial investments alongside their property holdings, the SPF provides a clean, compliant and well-understood structure under the law of 11 May 2007.
The SOPARFI (Société de Participations Financières)
Luxembourg’s operational holding vehicle, and the backbone of many cross-border wealth architectures. A SOPARFI benefits from Luxembourg’s extensive double tax treaty network (over 80 treaties) and from the participation exemption regime: dividends and capital gains from qualifying participations are exempt from corporate income tax, provided the holding meets certain thresholds (at least 10 % of share capital or an acquisition cost of €1.2 million, held for at least twelve months). For families holding property through subsidiaries in multiple countries, a SOPARFI can serve as the coordinating holding entity, centralising income flows and facilitating reinvestment.
The SCSp (Société en Commandite Spéciale)
A Luxembourg limited partnership with no legal personality, fiscally transparent and highly flexible. The SCSp is increasingly used as a co-investment or family pooling vehicle for real estate and private equity. It allows family members to participate as limited partners while the general partner — typically a family-controlled Sàrl — retains management control. Because the SCSp has no fiscal personality of its own, income is taxed directly at the level of each partner according to their own tax residence, avoiding double taxation and simplifying cross-border coordination.
The Luxembourg impatriation regime
For individuals relocating to Luxembourg, the impatriation regime (Article 115-13a LIR) offers significant tax advantages during the first eight years of residence: a participation premium of up to 50 % of annual fixed remuneration is exempt from income tax, along with partial exemptions for relocation costs and school fees. For families making a cross-border move and restructuring their property portfolio around a new centre of life, the impatriation regime can substantially reduce the effective tax rate during the transition period — a window during which many restructuring decisions are made.
Lombard lending
For portfolios that need liquidity without disposing of assets: a loan secured against a financial or property portfolio, enabling the financing of a project, an acquisition or a cash flow need without triggering capital gains and without altering the wealth allocation. Luxembourg’s private banking infrastructure makes Lombard lending particularly accessible, with competitive loan-to-value ratios and multi-currency flexibility. It is a balance-sheet management tool that we frequently incorporate into our recommendations.
Cross-border tax treaty coordination
Property income and capital gains are typically taxed in the country where the property is located (situs rule), but the interaction with the owner’s country of residence determines the effective tax burden. We map out the applicable treaty provisions for each property — France-Luxembourg, Italy-Luxembourg, Switzerland-Luxembourg, United Kingdom-Luxembourg, Spain-Luxembourg — to identify available tax credits, exemptions with progression, and timing opportunities. For families holding properties in three or more countries, this coordination layer is often where the most significant savings are found, and where the risk of double taxation is highest without professional advice.
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