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Where to Incorporate Your Offshore Company

View Offshore Information by Country/Jurisdiction:

Belize	British Virgin Islands	Cyprus
Delaware Non-Resident LLC	Gibraltar Tax Exempt Company	Gibraltar Non-Resident
Irish Domestic Companies	Isle of Man	Jersey
Liechtenstein Foundations	Luxembourg Holding Company	Netherlands Antilles
Panama	UK Managed Ltd Company	UK Non-Resident LLP

Luxembourg Holding Companies Fact File

Smallest of the Benelux countries. Founder member of the European Union. Centre of EU administration together with Brussels and Strasbourg. Financially dependent on EU institutions, financial services and heavy industry. One of the wealthiest countries in the world

Star Ratings:

• Corporate registration efficiency: 5 / 5
• Cost: 4 / 5
• Confidentiality: 3 / 5
• Local banking facilities: 4 / 5
• Legal system: 5 / 5
• Political stability: 5 / 5
• Reputation: 5 / 5

Location

Borders Belgium, France and Germany. Population 400,000.

Tax Planning Credentials

Luxembourg companies can be divided into two tax planning divisions:

(a) those that cannot benefit from Luxembourg's double taxation treaty network, such as 1929 holding companies, and

(b) those that can both benefit from such treaties and also EU directives and regulations such as 1990 societes des participation financiere (SOPARFI's).

From a tax planning point of view Luxembourg is ideally placed to benefit from EU directives and regulations but banking confidentiality is almost certain to be compromised as a result of pressure from particularly Germany. Companies - In Luxembourg there are two main types of company - Societes a responsibilite limitee (Sarl's) and societes anonyme (SA's). The former equates with a British limited liability company and the latter to a public limited company. The 1929 and 1990 holding companies are in fact not separate legal entities but merely fiscal elections.

The 1929 Holding Company - There must be a minimum shareholding of approximately €40,000.00. Generally there must be a participation interest of 25% or more. Borrowings must not be more than 3 times capital. Not as popular as they once were as no tax treaty benefits but they do benefit from unilateral tax relief which is why they are sometimes used with Dutch company structures.

The SOPARFI 1990 Holding Company - These benefit from both the Luxembourg tax treaty network and EU directives and regulations. In particular, they can benefit from the parent/subsidiary directive 90/435 which means that once certain criteria are satisfied a Luxembourg SOPARFI can receive dividend payments from other companies located in the EU without being subject to any withholding taxes. Technically, SOPARFI's are liable to full Luxembourg corporate tax at 33.3% but provided they have at least a 10% participation or an investment of approximately €1,600.000.00 there will be no Luxembourg corporate taxes to pay.

Advantages

• Highly developed infrastructure and pro-business government.
• Sophisticated and varied legal entities.
• Very stable economy.
• Banks have AAA status.
• The currency is the Euro.
• Little corruption.
• Beneficial or even share ownership need not be publicity recorded if using a SA.
• There are no nationality requirements in respect of most officerial positions.
• Full member of the EU benefiting from EU directives/regulations.
• Efficient local processionals.
• Excellent communications.
• English is widely spoken.
• Europe's largest financial services centre with Dublin.
• Large and sophisticated double taxation treaty network