Holding companies in Luxembourg: detailed overview of the SPF
Luxembourg private wealth management companies named SPFs in Luxembourg, are a form of holding company. These companies type are exempt of all taxes on income and from wealth tax.
Tax disputes
Due to the heterogeneity of the sources of Luxembourg tax law, tax litigation falls under two branches of the Luxembourg jurisdiction: administrative courts and judicial courts. Direct taxes fall under the jurisdiction or administrative courts, judicial courts have exclusive jurisdiction over ...
Tax losses
Tax losses incurred by a company during a tax year can be carried forward and, in principle, offset against taxable profits in subsequent years, thereby reducing the amount of tax payable. There are, however, restrictions on carry-forward and set-off. Tax losses incurred prior to 31st ...
Tax structuring of real estate investments
Owning real estate is more or less tax-efficient depending on the investment objective.
The transfer of a company's registered office
This transfer would therefore no longer result in immediate taxation of deferred profits and unrealised capital gains.
Tax integration
A tax integration regime is nothing more and nothing less than a tax consolidation of a group or part of a group of companies.
The tax authorities' invoking of directors' liability
The corporate director must be diligent and prudent, they must respect the obligations of its various missions.
DAC 6: Fiscally aggressive cross-border arrangements
The "DAC 6" Act (1) requires taxpayers and certain intermediaries to declare to the tax authorities any cross-border arrangements which are considered to be fiscally aggressive.It should be made clear from the outset that the three criteria listed must be met cumulatively in order for the whole ...
Taxation of income from capital reduction
When a company is set up, the share capital is formed by the contributions of the founders. Throughout the life of the company, the partners can increase the capital by new contributions but also by incorporation of reserves. The capital can also be reduced. In some cases, the income from a ...
Tax deductibility of operating expenses
The tax law allows companies to deduct operating expenses. These expenses are generated by the company in order to benefit it. An expense borne by the company but for the private needs of its manager is not deductible. For example, the manager of a company (SA, SARL) invites a client for lunch ...
Building sites abroad and the notion of permanent establishment
When a French company works on an assembly construction site in Luxembourg, is that company responsible for paying taxes in Luxembourg? When a Luxembourg company works on a construction site in France, is that company responsible for paying taxes in France? The answers to these questions can be ...
Luxembourg SOPARFI holding company taxation
Commercial and financial activities coexist in SOPARFI with the characteristic of having different tax regimes.
- 1
- 2
