Jurisdictions / Luxembourg
Europe's deepest fund and holding ecosystem, an ordinary corporate tax system, and 88 treaties. It is the right answer for investment structures far more often than for a single operating company — which is the distinction this page is built around.
The numbers people ask for on the first call. All current for 2026; a further one-point cut to the corporate rate has been announced for 2027.
An operating company, a subsidiary, or the first entity of a group. We tell you which legal form fits and what the running cost really is before anything is incorporated.
A SOPARFI sitting above operating subsidiaries, receiving their dividends and holding the eventual exit. This is the majority of what we do — and sometimes the answer is a Dutch B.V. instead.
A fund, a co-investment platform or a vehicle per deal. The first decision — regulated or unregulated — sets most of the cost, and it is hard to reverse after launch.
One early choice drives most of the cost: regulated or not. A SOPARFI or an SCSp runs lean. A SIF, RAIF or SICAR brings an AIFM, a depositary, an administrator and an auditor.
Fund vehicles are open to well-informed investors — a statutory category: institutional and professional investors, or others who confirm their status in writing and invest at least EUR 100,000.
People arrive here searching for an offshore company and find a jurisdiction that taxes at 23.87%. That is not a disappointment — it is the whole mechanism.
Luxembourg had an exempt vehicle once: the Holding 1929. It paid almost no tax, and because it paid almost no tax it was not a treaty resident and could not use the network it existed to reach. The European Commission found it incompatible with the common market in 2006 and it was gone by the end of 2010.
The SOPARFI that replaced it is a fully taxable, ordinary company — which is precisely why its dividends and exit gains can be exempt under Article 166 and why its treaty access holds up. If you need a structure that works only as long as nobody examines it, we are the wrong firm. How the SOPARFI works →
Thirty minutes, no charge. If the answer is a Dutch B.V. or a plain company at home, we will say so on the call.
Arrange a conversationA 5% participation threshold with no holding period, 98 treaties, and EUR 0.01 of capital. Often the better answer for a corporate holding.
The four rows that decide most cases, treaty rates by country, and four routes where the obvious answer is wrong.
How the layer works in general, what it has to satisfy after ATAD and the PPT, and why offshore stopped working.