EU's premier fund and IP holding hub. SOPARFI participation regime, 85+ treaties, AAA institutional credibility.
When Luxembourg is the right call, and when it is not.
Luxembourg is the largest fund domicile in Europe and second globally, supervised by the CSSF. UCITS, SIF, SICAR and RAIF wrappers cover retail, professional and private equity strategies, with the RAIF launching in roughly 6 weeks under an authorised AIFM.
The Luxembourg IP Box gives an 80% exemption on qualifying IP income for an effective rate near 5.2%, and the SOPARFI participation exemption covers qualifying dividends and capital gains. The 85-DTA network covers USA, UK, Germany and France.
SPF (private wealth vehicle) and SOPARFI structures combine with Luxembourg's deep private banking and trustee infrastructure. Luxembourg sits on standard US VC and PE term sheets for European holding entities.
Luxembourg requires a notarial deed, EUR 12K minimum share capital and realistic year-1 costs of EUR 10K-30K. For lean SME setups:
Luxembourg's combined CIT, municipal business tax and solidarity surcharge reach 24.94%. The IP Box and SOPARFI cut tax on IP and holding income, but operating profits remain taxed at headline rates. For low operating CIT:
Working data for Luxembourg. Cite check each figure before use.
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Each rate, threshold, and deadline below is cited from an authoritative source.
Information is provided for general guidance and reflects tax year 2025 unless noted. Specific situations require advice from a local practitioner. Always confirm against the cited tax authority and registrar before relying on a figure.