Holding structuring in Luxembourg, own, finance, protect.
Structuring a Luxembourg holding organises the ownership of assets and participations, intragroup financing and wealth protection around an efficient, treaty-eligible vehicle. FSL designs the structure, substance, accounting and compliance; legal opinions and reserved acts are coordinated with our partner lawyers and notaries.
Holding structuring designs a top company holding participations and assets, organising financing, flows and wealth protection. In Luxembourg the holding most often takes the form of a SOPARFI benefiting from the participation exemption.
Form governed by the amended law of 10 August 1915; participation regime art. 166 LIR; interest deduction limitation rule art. 168bis LIR (ATAD). Substance expected under the ATAD directives.
Key takeaway
- A Luxembourg holding is most often a SOPARFI.
- Intragroup financing must respect the interest limitation rule (art. 168bis LIR).
- A multi-tier holding ring-fences risk and organises exits.
Who this is for
- Groups consolidating the ownership of subsidiaries
- Family offices and corporate estates
- Investors structuring co-investments
- Entrepreneurs preparing acquisitions or a succession
What we do
- Ownership architecture (top holding, sub-holdings)
- Intragroup financing and flow scheme
- Tax scoping: participations, interest, withholding
- Substance, governance and compliance
- Accounting, consolidated accounts where relevant
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Preparation checklist
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Frequently asked questions
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