DTAX LUXEMBOURG
Luxembourg tax & corporate structuring for private clients and their holdings.
DTAX Luxembourg — Our Expertise
Request a ConsultationLuxembourg Entities & Holdings
SOPARFI / SPF design, governance, and substance to support private wealth and participation management.
ExploreCross-Border & Residency (BE–LU)
Residence tests, tie-breakers, documentation, and advance decisions for legal certainty.
ExploreTransactions & Financing
Reorganizations, M&A, shareholder movements, and intra-group financing with compliant substance.
ExploreCompliance, VAT & Rulings
Corporate/VAT filings, governance packs, and advance tax rulings to de-risk implementation.
ExploreDTAX 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
FAQs
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A Luxembourg vehicle becomes relevant when activities, holdings, or investments cross borders — for example, managing EU subsidiaries, holding intellectual property, or centralizing family assets. We assess each situation to confirm whether Luxembourg adds value beyond Belgium’s framework.
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DTAX operates in close partnership with DCA in Belgium. Our teams synchronize accounting, filings, and tax positions across both jurisdictions, ensuring that decisions taken in one country remain compliant and optimized in the other. You always retain one central contact.
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We prepare and manage the full process — from feasibility review to submission and follow-up with the Luxembourg authorities. DTAX handles rulings, transfer-pricing documentation, and regulatory compliance under strict confidentiality and traceable communication.
