Luxembourg Holding Companies Domestic and International Tax Aspects

All you need to know about holding companies.

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.

1. Why do we use holding structures?
2. How to finance them in a tax efficient manner?
3. What are the latest anti-avoidance rules developed that may threaten a Luxembourg holding company?
4. 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)?

Auteur: Olivier dal Farra