Lawyer specializing in Franco-Luxembourg taxation: holding companies, cross-border flows and structures

Between France and Luxembourg, the tax interest of a structure depends less on the existence of a vehicle than on the function it actually fulfils in the heritage or entrepreneurial organisation.

Holding, investment company, financing, dividend recovery, disposal of shares or reinvestment: each choice must be assessed at the scale of the whole scheme, with particular attention to substance, flows and exit taxation.

A Luxembourg structure of value only if it serves a strategy

The interposition of a Luxembourg entity may meet the objectives of holding, financing or investment. However, its tax efficiency depends on how it relates to the taxpayer's residence, the location of the assets and the nature of the income concerned.

The question is therefore not whether Luxembourg is in itself fiscally attractive, but whether a Franco-Luxembourg architecture makes it possible to improve the net result of the project.

Organize streams without losing sight of output

Effective structuring must include taxation of dividends, interest, capital gains and future operations from the outset. An economy obtained on a flow can lose any interest if it is neutralised on a disposal, distribution or subsequent reorganization.

The firm intervenes on this dimension of fiscal strategy in order to confront the different schemes, to identify the margins of optimization actually available and to retain an architecture consistent with the economic or heritage objectives of the customer.

Master Edouard Pruvost specializes in international tax strategy advice. To structure an operation, holding or investment between France and Luxembourg in a fiscal optimisation logic, contact the firm to define a strategy adapted to your objectives.