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Luxembourg
"Luxembourg fund structure gave us access to institutional capital globally. Regulatory framework and service provider ecosystem are world-class."
Company Formation & Holding Structures
- S.à r.l. (private limited company) or SA (public limited company) for general holding structures
- SOPARFI (Société de Participations Financières): holding company with participation exemption
- 24.94% corporate tax rate (includes municipal business tax)
- Participation exemption: 0% tax on dividends and capital gains from qualifying subsidiaries (>10% holding or €1.2M+ acquisition cost, 12-month holding period)
- 0% withholding tax on dividends paid to non-residents and qualifying EU parents
- Extensive treaty network for dividend, interest, royalty withholding tax reduction
Investment Funds & Vehicles
- SICAV (Société d'Investissement à Capital Variable): Variable capital investment company, most common fund structure
- SIF (Specialized Investment Fund): For well-informed investors, lighter regulatory regime
- RAIF (Reserved Alternative Investment Fund): No prior regulatory approval required, flexible
- SCS/SCSp (partnerships): Used for private equity, real estate, venture capital funds
- Regulated by CSSF (Commission de Surveillance du Secteur Financier)
- Leading domicile for UCITS funds, alternative funds, private equity vehicles globally
Tax & Regulatory Benefits
- No capital gains tax on sale of shares if participation exemption applies
- No withholding tax on dividends to non-residents
- Interest and royalty payments: 0% withholding under EU directives and treaties
- VAT exemption for regulated fund management services
- Substance requirements: local directors, office, service providers (manageable with professional support)
- Regulatory expertise and deep service provider ecosystem (administrators, depositary banks, auditors)
Banking & Financial Ecosystem
- Premier private banking center (150+ banks including all major international institutions)
- Deep expertise in custody, fund administration, wealth structuring
- Multilingual workforce (Luxembourgish, French, German, English)
- Political stability, AAA credit rating
- High operating costs but justified by regulatory quality and market access
- Gateway for cross-border finance, asset management, family office structures
Work With Us
Take Control of Your Global Wealth and Legacy
We connect you with professionals who build structures that work, across borders, under scrutiny, and built to last.
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Important Notice: Aventarys Group connects clients with licensed third-party professionals. We do not provide legal, tax, accounting, or financial advice. All services are delivered by independent licensed providers. Clients should consult their own legal and tax advisors before making any decisions.
