TaxLegal and tax navigator
A practical Luxembourg navigator for SARL and SA formation, holdings, SPFs and funds, private banking, corporate accounts, taxation and CSSF regulation.
Legal and business review
A Luxembourg structure needs a genuine business or family function. Legal form, effective management, funding, participation-exemption eligibility, cross-border payments, UBO disclosure, regulated services and bankability should be settled before incorporation.
Luxembourg is an EU state with multilingual legal and financial infrastructure. Luxembourg Business Registers administers the RCS, RESA and RBE; ACD and AED administer tax; banks, investment firms, funds, managers, PIs and EMIs fall within the CSSF perimeter, while insurance has a separate supervisor.
A closely held business commonly uses an SARL with EUR 12,000 minimum capital; an SA, SAS, SCA or partnership may suit capital raising and more complex governance. The notarial deed, RCS/RESA, business permit, UBO, tax, accounting and annual reporting route is mapped before launch.
Open detailed section →A registered office does not prove tax residence or treaty entitlement. Board process, authority, local decisions, directors, people, premises, expenditure, contracts and risk control should match the company's group function and be evidenced.
The bank or provider is checked in the CSSF's official database. Companies and private clients prepare an ownership chart, RBE evidence, source of wealth and funds, business plan, financials, tax residence, counterparties and projected flows; each bank may decline under its risk policy.
Open detailed section →An SPF is designed to manage personal investment wealth for eligible investors and is not an operating trading company. A SOPARFI is an ordinary fully taxable company that may access relief where conditions are met. Funds, insurance, fiduciary arrangements and foreign trusts require separate classification.
Open detailed section →UCITS, Part II UCIs, SIFs, SICARs, RAIFs and other AIFs differ by authorisation, investor eligibility, manager, depositary, reporting and marketing. A RAIF is not directly authorised by the CSSF as a product but must use an authorised external AIFM and comply with its statutory framework.
From 2025 the headline corporate income-tax rate for taxable income above EUR 200,000 is 16%, plus the 7% employment-fund surcharge and communal business tax. The Luxembourg City combined nominal example is 23.87%; the actual burden depends on municipality, base, funding, reliefs and net wealth tax.
Open detailed section →An SPF pays annual subscription tax at 0.25% of the statutory base, subject to a EUR 1,000 minimum and EUR 125,000 maximum. Investor and activity restrictions are material; the regime does not displace owner taxation, CFC, beneficial-ownership or family-residence rules.
Standard VAT is 17%, with 14%, 8% and 3% rates for specified categories. Place of supply, intra-EU transactions, imports, reverse charge, financial exemptions and input recovery depend on the supply chain and customer status.
A company reports and updates its beneficial owners in the RBE. Banks and professionals review ownership, PEPs, sanctions, countries, capital origin and economic purpose; CRS, FATCA, DAC6 and other exchange rules are tested for each vehicle's role.
Payment services, e-money issuance, investment services, fund management and crypto-asset services require a CSSF perimeter analysis. Capital, governance, local substance, safeguarding, outsourcing, IT, AML and EEA passporting are designed for the relevant licence.
The sequence links objectives, owner and asset countries, form, notary and providers, tax model, business permit, RCS/RBE, banking file, funding, transfer pricing, agreements, reporting and the annual compliance calendar.
Solutions for international business
The legal system and corporate law determine which vehicle can be formed, how assets are controlled, which licences are required and whether the structure is bankable.
We select an LLC, corporation, partnership, branch, holding or special vehicle and prepare constitutional documents, governance, UBO and approvals.
↗02We compare control, asset ownership, beneficiaries, succession, tax, substance and bankability.
↗03We select an institution for the relevant countries and flows, prepare ownership, business model and source-of-wealth/funds files, and support onboarding.
↗04We classify banking, payment, investment, fund, insurance and other regulated functions and design the licensing and compliance route.
↗Formation, licensing and account opening remain subject to the decision of the relevant authority, regulator or financial institution.
Discuss an international structureInternational tax expertise
A headline rate is only the beginning. Test the full life cycle before choosing a company, fund, bank or place of management.
New rules, effective dates and transition provisions.
Rates, base, special regimes, minimum tax and sector rules.
Management, agents, premises, people, construction and services.
VAT/GST, sales tax, customs, excise, property and registration charges.
Recognition, depreciation, interest, provisions and loss relief.
Consolidation, intra-group transfers, M&A, financing and exit.
Eligibility, real activity, people, expenditure and preservation of relief.
Dividends, interest, royalties, services, capital gains and branch remittance.
Related parties, arm’s length, documentation, DEMPE and treaty entitlement.
Registration, returns, deadlines, audits, penalties, objections and litigation.
Presence days, domicile, permanent home, centre of interests and treaty tie-breakers.
Employment, director fees, business, investments and property.
Allowances, reliefs, pension and insurance contributions.
Capital gains, wealth, property, inheritance and gift taxes.
Foreign tax credit, exemption, treaties and residence certificates.
Returns, instalments, notifications, foreign assets and sample computation.
The outcome depends on the facts, source, residence, applicable treaty and law in force on the transaction date.
Primary sources
Open the regulator and tax-authority documents supporting the country overview. Applicability is tested separately for each transaction.
Banking support
We align a company, SPF or fund with tax, licensing and bank requirements and prepare ownership, capital-origin and transaction evidence. The financial institution makes the final account-opening decision.
Discuss opening an accountThe information is general in nature, does not constitute legal or tax advice and should be verified as of the date of the specific transaction.