Gaëtan Molina | Lawyers

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"I focus on the tax aspects of investment fund structures and private equity transactions. I help clients design efficient cross border structures, manage tax risk and navigate constantly changing rules. My background in both French and Luxembourg tax law means I can bridge different market practices and expectations. I enjoy working closely with clients and colleagues from the outset of a project to find clear, practical tax solutions that support their commercial goals."

Overview

Gaëtan is a Managing Associate in the Luxembourg tax practice. He advises multinational groups, private equity firms, investment managers and other corporates on a wide range of Luxembourg and international tax matters.

His work focuses on the tax structuring of investment funds and private equity platforms, including fund formation, investment and divestment structures and restructuring transactions. He helps clients manage tax opportunities and risks in cross border investments, often involving multiple jurisdictions and complex stakeholder expectations.

Before joining Linklaters Luxembourg in 2021, Gaëtan gained experience in tax law at several law firms in France and Luxembourg. This background gives him a strong understanding of common cross border structuring approaches, which he uses to deliver clear and actionable advice to clients.

Experience

Yondr Group Limited: advising a global developer, owner and operator of hyperscale data centres on the refinancing of its two data centres located in Slough, England, through a £532 million public ABS issuance.
A major global specialised infrastructure debt fund: advising on the establishment, structuring, negotiations and first close for a private specialised infrastructure debt fund focusing on originating and investing into debt Investments where the underlying assets have infrastructure or infrastructure-like characteristics.
A major global private credit fund: advising on the establishment, structuring, negotiations and first close for a private direct lending fund focusing on a diversified portfolio of loans to U.S. sponsor-backed middle market corporate borrowers as well as other opportunistic investments.
BlackRock Investment Management (UK) Limited: advising from a Luxembourg tax point of view on the structuring and establishment of the first European Long Term Investment Fund of Blackrock open for retail investors. The ELTIF follows a private equity strategy through co-investments with different investment vehicles of Blackrock, thus giving an opportunity to retail investors to participate in alternative investments.
Ardian: advising on the $575m acquisition of Verne from Digital 9 Infrastructure plc. The Linklaters Luxembourg Tax team designed and set up a Luxembourg investment structure and advised on financing and syndication.
Stoneshield Capital: advising on the €300m transfer of its Spanish real estate portfolio via share and forward purchase agreements, and leases to MiCampus Living. The Luxembourg Tax team devised a customised Luxembourg structure for the acquisition of seed and future core-plus assets.
Ares Management Corporation: advising on structuring a new investment platform for Ares Fund VI (€1bn+) acquisitions in Spain and co-investment schemes. A distinctive Luxembourg-Spanish SOCIMI structure was implemented.
Antin Infrastructure Partners: advising a French leading private equity fund focused on infrastructure investments, on the formation of a joint venture vehicle with Scandinavian Enviro Systems and the support of Michelin aimed at establishing end-of-life tires recycling plants across Europe, with a total capacity to recycle up to one million tons of end-of-life tires annually by 2030 to accelerate the circular economy in the tires industry. The first plant, located in Sweden, is expected to be fully operational by 2025.
Carlyle: advising sponsor and manager on structuring, establishment and fundraise of a semi-liquid private equity fund available to retail investors, Carlyle Private Equity Partners.

Education, Qualifications and Languages

Gaëtan holds a Master’s degree in Tax Law from the University of Lille (2018) and a Master’s degree in Corporate Law from the University of Aix Marseille (2017).

Gaëtan was admitted to the bar of Paris in 2022 and bar of Luxembourg in 2025.

He speaks French and English.

Thought Leadership

Published article: Exchange of information on request: evolution of the legal framework and current trends. Access it here

Experience

Yondr Group Limited: advising a global developer, owner and operator of hyperscale data centres on the refinancing of its two data centres located in Slough, England, through a £532 million public ABS issuance.

A major global specialised infrastructure debt fund: advising on the establishment, structuring, negotiations and first close for a private specialised infrastructure debt fund focusing on originating and investing into debt Investments where the underlying assets have infrastructure or infrastructure-like characteristics.

A major global private credit fund: advising on the establishment, structuring, negotiations and first close for a private direct lending fund focusing on a diversified portfolio of loans to U.S. sponsor-backed middle market corporate borrowers as well as other opportunistic investments.

BlackRock Investment Management (UK) Limited: advising from a Luxembourg tax point of view on the structuring and establishment of the first European Long Term Investment Fund of Blackrock open for retail investors. The ELTIF follows a private equity strategy through co-investments with different investment vehicles of Blackrock, thus giving an opportunity to retail investors to participate in alternative investments.

Ardian: advising on the $575m acquisition of Verne from Digital 9 Infrastructure plc. The Linklaters Luxembourg Tax team designed and set up a Luxembourg investment structure and advised on financing and syndication.

Stoneshield Capital: advising on the €300m transfer of its Spanish real estate portfolio via share and forward purchase agreements, and leases to MiCampus Living. The Luxembourg Tax team devised a customised Luxembourg structure for the acquisition of seed and future core-plus assets.

Ares Management Corporation: advising on structuring a new investment platform for Ares Fund VI (€1bn+) acquisitions in Spain and co-investment schemes. A distinctive Luxembourg-Spanish SOCIMI structure was implemented.

Antin Infrastructure Partners: advising a French leading private equity fund focused on infrastructure investments, on the formation of a joint venture vehicle with Scandinavian Enviro Systems and the support of Michelin aimed at establishing end-of-life tires recycling plants across Europe, with a total capacity to recycle up to one million tons of end-of-life tires annually by 2030 to accelerate the circular economy in the tires industry. The first plant, located in Sweden, is expected to be fully operational by 2025.

Carlyle: advising sponsor and manager on structuring, establishment and fundraise of a semi-liquid private equity fund available to retail investors, Carlyle Private Equity Partners.

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