Luxembourg holding companies domestic and international tax aspects

Olivier Dal Farra

262 pages, parution le 24/01/2023

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Résumé

In a global economy, international holding structures have become vital for investors to meet the everchanging economic challenges and to survive on competitive international markets. In many international groups, for private equity firms and for many high-net-worth individuals, holding companies are at the cornerstone of the business and tax management of their investments.

Luxembourg is a major holding location used by multinationals and international investors for structuring their investments. Luxembourg holding structures have been used successfully by thousands of investors for decades. Yet, the fiscal legislation applying to them is in constant evolution, both from a Luxembourg and an international tax standpoint, and the efficient use of Luxembourg holding companies has nowadays become full of difficulties and pitfalls.

Why do we use holding structures? How to finance them in a tax efficient manner? What are the latest anti-avoidance rules developed that may threaten a Luxembourg holding company? How are holding structures impacted by the DAC6 legislation on aggressive tax planning and could be impacted by the future Unshell proposal of EU Directive (ATAD3)?

The knowledge and skills of tax advisors require an appropriate balance between understanding tax planning opportunities while maintaining a structure robust and compliant with the latest OECD and EU anti-abuse rules.

This book is a practical guide that is purposed to gather, comment and explain the taxation of Luxembourg holding companies. It is designed to help investors, advisors, private bankers, domiciliation companies to grasp the tax implications and challenges related to planning and operating a Luxembourg holding structure

The internal layout of the book integrates the dual aspects of tax law in each chapter from the set-up to the end of the Luxembourg holding structure (explaining both the tax planning possibilities and conversely the anti-abuse risks). An emphasis is made on economic substance and the possible impact of the Unshell proposal of EU Directive (ATAD3). A complete point is made on the DAC6 aspects and hallmarks applicable to Luxembourg holding companies, including illustrative examples.