Luxembourg Accounting, Tax & Corporate Structuring

DTAX Luxembourg — Our Expertise

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Luxembourg Entities & Holdings

SOPARFI / SPF design, governance, and substance to support private wealth and participation management.

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Cross-Border & Residency (BE–LU)

Residence tests, tie-breakers, documentation, and advance decisions for legal certainty.

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Transactions & Financing

Reorganizations, M&A, shareholder movements, and intra-group financing with compliant substance.

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Compliance, VAT & Rulings

Corporate/VAT filings, governance packs, and advance tax rulings to de-risk implementation.

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DTAX Detailed Services

Luxembourg-focused advisory for private clients and their structures, coordinated with Belgian positions where relevant.

Luxembourg Entities & Holdings (SOPARFI / SPF)

Design and governance of participation holding structures, including board process, substance, and documentation trails to support tax positions.

  • Articles, shareholders’ agreements, and governance packs
  • Substance: directors, minutes, location of decision-making
  • Cash flow, dividend policy, and treaty navigation

Cross-Border & Residency (Belgium–Luxembourg)

Residence tests, tie-breakers, center-of-life evidence, and filing positions across jurisdictions. We prepare documentation to substantiate residency and avoid double taxation.

  • Residence analysis and documentation checklist
  • Dual-tax situations and treaty application
  • Advance discussions / decisions for certainty

Transactions & Reorganizations (Lux)

Tax-efficient buy/sell structuring, mergers, de-mergers, contributions, and shareholder movements implemented under Luxembourg law and practice.

  • Neutrality paths, withholding outcomes, and exit routes
  • Coordination with counsel and notaries through completion

Intra-group Financing & Substance

Financing flows, interest-deductibility considerations, documentation, and governance to support arm’s-length conditions and substance requirements.

  • Board process, pricing files, and intercompany documentation
  • Cash-pool interfaces and withholding mapping

Compliance, VAT & Filings

Corporate and VAT registrations, periodic returns, and governance packs coordinated with accounting teams.

  • VAT profiling and returns
  • Corporate filings and shareholder records

Advance Tax Rulings (Lux)

Feasibility, data preparation, and filing/interaction management to secure clear, predictable outcomes for transactions and structures.

  • Scoping, draft submission, and Q&A coordination
  • Alignment with Belgian positions where relevant

Governance & Documentation Packs

Director mandates, minutes, registers, and decision paper trails that support substance, filings, and audit readiness.

  • Annual cycle: board, shareholders, approvals
  • Document retention and evidence frameworks

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