Study: Real Estate Holding Restructuring

Context

• Holding structure: approximately 30 subsidiaries and partnerships

• Portfolio: Core+ logistics assets, offices, and project developments

• International scope: Netherlands, Spain, Poland, Namibia, Luxembourg

• Stakeholders: tax/legal advisors, notary, banks & insurers, Dutch Tax Authority, ERP

  vendor, internal finance team

Project Objectives

• Prepare the group for shareholder-director retirement and ensure business continuity

• Design a structure enabling ownership dilution via a Luxembourg fund

• Prepare the organization for future financing and growth

• Execute two tax-approved demergers (following Dutch Tax Authority ruling)

• Implement internal and cross-border restructurings across Europe and Africa

Key Responsibilities

Complex Financial & Tax Topics

• Preparation of demerger balance sheets

• Corporate income tax (CIT) & Reinvestment reserve (tax deferral provision) positions

• Translate tax rulings into practical action items

Transaction & Demerger Dossier

• Develop legally, fiscally, and financially substantiated documentation

• Act as liaison between notary, tax advisors, banks, Dutch Tax Authority, and investors

Managing Restructuring Transactions

• Lead two complex demergers (NL/Lux tax rulings)

• Execute internal and cross-border reorganizations

• Manage national and international stakeholder alignment

• Incorporate new entities

• Gather and implement international legal and tax advice

  
  

ERP & Administration

• Set up new administrations in Informant ERP

• Optimize existing accounting processes

• Support and guide the internal finance team

Results & Impact

• Successful execution of multiple complex demergers with Dutch Tax Authority rulings

• Governance and structure established for future growth and financing

• Alignment of stakeholders across the Netherlands, Luxembourg, and Africa

• Continuity and long-term value creation secured for the real estate holding