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Luxembourg Bank Account

140.00 500.00

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We work with banks that are not subsidiary of your home country bank groups. This greatly enhance privacy and secrecy

Our clients, who use the Bank Introduction Service, are not required to visit the bank in person

 

Account features:

24 hours / 7 days On Line Banking
Strong bank secrecy and privacy
Allows you to send and receive international payments SWIFT
Multi-currency (EUR, USD , GBP, etc. )
Visa/Mastercard ATM International debit cards
Visa/Mastercard Credit Cards (optional)

 

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Who can open a Luxembourg bank account?

Everyone can open an account at a bank in Switzerland. However, banks reserve the right to reject customers. For example, a bank might refuse to offer banking services to a so-called “politically exposed person” who the bank believes would pose a “reputation” risk if he or she were to become a client. A bank might also refuse to start a banking relationship if it has doubts about the origins of the potential client’s funds. Swiss banks are forbidden by law to accept money which they know or must assume stem from crime or any illegal activities.

 

How can I open an account from my home country?

Swiss banks have procedures concerning the opening of accounts, irrespective of the domicile of the customer. In line with Swiss laws governing “due diligence”, the bank must verify the identity of the customer on the basis of an official document (e.g. a passport and confirmation of residential address).

 

 

What are the main benefits of banking offshore?

PRIVACY, SECURITY & ANONIMITY

Offshore banks have the highest bank secrecy to protect their clients. No client informations are disclosed.

TAX EFFICIENCY

Banking offshore could be the best way to manage your funds in regards of tax optimization. We understand that each client has their own needs and reasons for banking offshore. You may want a tax haven to benefit form zero taxation. You may want the strict bank secrecy the offshore countries offer, you may want to internationalize your business or you may want to have access to financial services that aren’t available locally. Whatever your reasons, our professionals help you to realize your need and goals and grow and protects your wealth.  

Can you open the account without having to visit the bank personally?

Of course, all the accounts (exluded hnwi accounts)  we support to open do not require the physical presence of the owner.

 

 

Can an account by opened anonymously in Luxembourg?

No, that is not possible. Banks follow so-called “know-your-customer” rules which require staff to identify the person opening an account and, where necessary, to establish the identity of the beneficial owner. Incidentally it was the banks themselves who drew up the extremely strict, internationally recognized rules for verifying the identity of their clients as a deterrent to money of criminal origin.

 

Does bank  secrecy shield criminals?

No. Bank customer confidentiality has never been absolute. Swiss banks are obliged, for example, to disclose information in criminal proceedings against their clients. This is an absolute obligation, regardless of whether the offence was committed in Switzerland or abroad. Compared with other countries Switzerland has always been very successful at combating organized crime and money laundering. Switzerland is one of the cleanest financial centers in the world.

 

What documents are required to open the swiss personal bank account?

  • Passport.
  • Copy of utilities must be no longer than three months old. You may need to have these documents certified.

 

What means certificated/notarized documents?

Certification means that a bank official, cpa, attorney at law, notary public, attests that the documents are true. As example, for each documents he writes:  “I hereby certify this is the true copy of Mr. First Name, Last Name”. This comes with signature, date and professional stamp .

What documentation will the bank want to see?

As mentioned above, Luxembourg banks are obliged to verify the identity of a client. The bank will want to see official identification papers such as a valid passport or an equivalent official identification document containing a photograph. The bank may also ask for documentation that can prove the origin of your funds, such as the contract for a house sale, a statement from a foreign bank, a receipt from the sale of securities, etc.

 

What questions will the  bank ask me?

First of all, the bank’s staff will certainly ask questions to fulfill the bank’s legal obligations with regard to due diligence. This will include asking for proof of your identity and also establishing the identity of the beneficial owner of the assets if you are depositing funds on behalf of someone else. The bank’s staff might also ask about the origin of the funds and the nature of your professional business and they will also want to get an idea of your usual financial transactions. In order to offer you the best advice, the bank will also ask about your future plans, for example, whether you intend to buy a house, start a business, retire, etc. If you are asking the bank to manage an investment portfolio they will also ask how much risk you are willing to accept. In short, the more the bank knows about you, the more it can tailor its advice and service to your individual needs.

 

Is the opening guaranteed?

Yes the opening is guaranteed or You will get 100%MoneyBack. Paypal payments are welcome

How long does it take to open an account?

From few working days up to 3 weeks.

What are the fees applied by the Luxembourg banks?

Swiss banks have competitive fees and higher interests rates  compared to the banks around the corner

How can I withdraw money from my  bank account?

ATM card and credit card valid in all the world.

Can I open a Luxembourg account as a non resident ?

Sure , almost all our clients are non-residents. We have clients in many countries.

I’m Indian (south african, brazilian, etc,etc) citizen, can I still open the  account ?

Yes, you can.

Do you have a Luxembourg bank account? Should you pay tax?

If you receive savings and investment income from abroad, you will usually need to declare this on a Self Assessment (SA) tax return. You may have to pay  Income Tax, but if you’ve paid foreign tax on the income you may be able to offset (deduct) this.

Does the  account have on-line banking?

Yes all account have on-line banking 24 hours/ 7 days always available.

Can I close my Lux account whenever I wish ?

Sure There are no restrictions when it comes to closing an account in Offshore countries. You are free to close your account if you wish. The procedure is immediate and cost-free. Of course, if your money is invested, it generally takes a few days to liquidate positions, but even so, no one will prevent you from withdrawing your funds or charge you a financial penalty.

Which  Luxembourg bank will account be opened with ?

We have a large network of banks in Offshore countries.

Many of which have been in operations for over 100 years. Our company will select the bank with the best conditions at present from a permanently updated list of banks with the best price-ratio. We work with banks in all categories. Which bank is right for you depends on many factors, such your country of tax residence, where you reside, eventual treaties of exchange information that have been signed, how much you plan to deposit and what kind of operations will you perform with funds.

Can I choose the Luxembourg bank ?

Yes you can choice bank. We do not, however, give out the names of the banks before you actually pay in full an order. Each account we offer can be opened with different  banks in the same country We select the bank that suits better the client needs and minimum deposit requirements. We do not offer “mass product”. We select the banks with the best conditions at present from a permanently updated list of banks with the best privacy&security policy.

 

Account Opening Procedures & Requirements

Opening an offshore bank account via distance banking is slightly more cumbersome when compared to opening a domestic bank account, considering one actually walks into a branch when opening a domestic bank account. As one of the oldest professional offshore banking service providers & incorporation agents on the web, we have relationships with major offshore banks and financial institutions around the world, and stand ready to assist you every step of the way during the account opening process.

Generally speaking the procedure to open an offshore bank account consists of properly preparing and submitting the following documents:

Notarized copy of the Certificate of Incorporation and/or Articles of Association (for corporate accounts)
Certified copy of your government issued passport (for both personal and/or corporate accounts)
Original Utility Bill (for both personal and/or corporate accounts)
Bank or professional reference for the account signatory (for both personal and/or corporate accounts)
Completed banking applications and forms which we provide and assist in completing

Bank Due Diligence requirements

To comply with legislations, banks must collect adequate due diligence to verify the identity of the ultimate beneficial owners and controllers of the potential client wanting to establish a relationship with the bank. Below is the documentation required for the various types of entity the potential client may be established as.

Limited Company – please provide certified copies of the following: a) Certificate of Incorporation, b) Memorandum and Articles of Association, c) Register of Directors, and d) Register of Members. For at least two of the entity’s directors, for shareholders with an interest equal to or greater than 10% and for all other authorised account signatories please provide certified copies of the items laid out at i) through iv) below.
Limited Liability Company – please provide certified copies of the following: e) Certificate of Incorporation, f) Operating Agreement, and g) Schedule showing the members and their respective percentage interests. For at the entity’s managing member, for members with an interest equal to or greater than 10% and for all other authorised account signatories please provide certified copies of the items laid out at i) through iv) below.
Limited Partnership – please provide certified copies of the following: h) Certificate of Registration (where available), i) Limited Partnership Agreement, and j) Schedule showing the limited partners and their respective percentage interests. For the general partner, limited partners with an interest equal to or greater than 10% and for all other authorised account signatories please provide certified copies of the items laid out at i) through iv) below.
Trust – please provide a certified copy of the declaration of trust or deed of settlement as appropriate, and for any of the trust’s settlor, beneficiary(s) with a vested interest and for all other authorised account signatories please provide certified copies of the items laid out at i) through iv) below.
Foundation – please provide certified copies of: k) Certificate of Registration, l) Charter of the Foundation, and m) Register showing the Council of Members. For at least two of the Council of Members, beneficiaries and for all other authorized account signatories please provide certified copies of the items laid out at i) through iv) below.
Individuals – please provide certified copies of the documents below: i) Passport or drivers license, bearing their signature and photograph, AND one of the following to verify their residential address (PO boxes are not acceptable); ii) Recent (less than 3 months old) utility bill, OR iii) Recent (less than 3 months old) bank or credit card statement, OR iv) Reference from a ‘respected professional’ (lawyer, accountant or manager/director of a regulated financial institution), who has known the person for at least 2 years.
Funds If the potential client is a fund, instead of item d), g) or j) and due diligence on investors, i.e. items i) through iv) as specified, an AML comfort letter is required from the fund’s administrator or transfer agent confirming that they are responsible for performing due diligence on the fund’s investors – we have a standard template available for this. Where the potential client has an entity as either a director or shareholder, documentation as outlined above is required for that type of entity. If the potential client is a regulated financial institution we may be exempt from collecting due diligence on it. Source of funds Please ensure that sufficient, relevant information on the source of funds to be deposited with banks is provided with the application form.
Bearer Shares Most banks are unable to provide services to entities that have issued bearer shares; these must either be immobilized or cancelled and reissued to persons. Entities that haven’t, but are capable of issuing bearer shares must undertake not to issue bearer shares, or upon their issue the account(s) will be frozen until the bearer shares are either immobilized or cancelled.
Certification/Notarization of Documents The certifier (notary public, lawyer, accountant, manager/director of a regulated financial institution, for example) is to attest that the documents are a true copy of the original, sign each document, print their name underneath, indicating their position or capacity and include a contact address and phone number.

http://www.financialsecrecyindex.com/database/Luxembourg.xml

Overview of the Secrecy Jurisdiction
Summary
30 History as Secrecy Jurisdiction Since 1929 [Notes]
A statue dating from 31 July 1929 introduced the 1929 holding companies in Luxembourg (OffshoreSimple). In the same year, Lowtax.net reports that the Luxembourg stock exchange opened: “The Luxembourg Stock Exchange was founded in 1929 and lists equities, investment fund shares and, especially, Eurobonds.” (Lowtax.net).
31 Development and Role as a Secrecy Jurisdiction [Notes]
Luxembourg’s financial centre plays an extraordinary role in world finance. Spears magazine wrote in 2008 on Luxembourg: “Unlike chic Monaco, with its emphasis on individual HNWs [High Net Worth Individuals] – as opposed to their businesses – Luxembourg embraces corporates. Bring your holding companies, your hedge funds yearning to be free. […] In recent years, Luxembourg’s government has redefined its brand of holding companies, replacing the 1929 original with a pragmatic type of company called a Family Private Assets Management Company (SPF). These stand outside corporation tax, municipal business tax, wealth tax and withholding tax, provided they do absolutely nothing except shuffle share and bond certificates in Luxembourg.
Companies that want to have some activity while retaining tax transparency are also catered for. Limited partnerships (SeCS) are liable for none of the three main taxes, and foreign capital gains may also escape tax. But Luxembourg comes into its own with hedge funds. Undertakings for Collective Investment (UCIs) have €2 trillion (£1.6 trillion) under their control as of May this year [2009], far more than equivalents in France or Britain. The taxation on UCIs is negligible, although the ubiquitous EU Savings Tax Directive is bearing down on some. Eric Fort, tax partner at one of Luxembourg’s biggest legal advisers, Arendt and Medernach, says that Luxembourg has a perpetually pro-investor political class: ‘We have a serious legislature but it’s as flexible as possible. The administration is pretty investor-minded and proactive.” (Spears WMS; [TJN-note]).
INCSR wrote in 2013: “Despite its standing as the second-smallest member of the European Union (EU), Luxembourg is one of the largest financial centers in the world. It also operates as an offshore financial center. Although there are a handful of domestic banks operating in the country, the majority of banks registered in Luxembourg are foreign subsidiaries of banks in Germany, Belgium, France, Italy, and Switzerland. While Luxembourg is not a major hub for illicit narcotics distribution, the size and sophistication of its financial sector create opportunities for money laundering, tax evasion, and other financial crimes” (INCSR 2013: 158). In addition to this, the report noted “The GOL [Government of Luxembourg] should continue to increase the quantity and quality of its reporting. The GOL also should ensure financial sector supervisory authorities conduct more on-site AML/CFT inspections and address concerns about beneficial ownership of legal persons on various accounts” (ibid.: 160).
In 2008, the INCSR gave some more details on the scope of Luxembourg’s financial industry: “With over U.S. $3.1 trillion in domiciled assets, Luxembourg is the second largest mutual fund investment center in the world, after the United States. As of October 2007, 157 registered banks existed, with a collective balance sheet total reaching approximately U.S. $1.38 trillion. In addition, as of January 2007, a total of 2,238 ‘undertakings for collective investment’ (UCIs), or mutual fund companies, whose net assets had reached over approximately U.S. $2.66 trillion operated from Luxembourg or traded on the Luxembourg stock exchange. Luxembourg has approximately 15,000 holding companies, 95 insurance companies, and 260 reinsurance companies. In January 2006, the Luxembourg Stock Exchange listed over 39,000 securities issued by nearly 4,100 entities from 105 countries. Luxembourg also has 116 registered venture capital funds (Societe d’investissement en capital a risqué, or “SICAR”).” (INCSR 2008: 314).
With respect to the investment fund industry, the IMF provided some more details in 2011: “Luxembourg is the world’s second largest center for investment funds after the United States. Investment funds domiciled and marketed in Luxembourg account for about 70 percent of its total financial sector assets, and about 30 percent of total assets under management by European funds. Fund sponsors mainly originate from Europe and the United States. Funds domiciled in Luxembourg are generally managed from other international financial centers. Fund shares are distributed in other European countries through an extensive use of the European passport, as well as to investors worldwide (particularly Asia).” (IMF 2011: 8).
One type of mutual funds which is commonly used in Luxembourg is called “Undertaking for Collective Investment” (UCI). Lowtax.net reports on those: “The various forms of UCI are all exempt from all Luxembourg taxation, and pay only a small capital duty on start-up, plus an annual tax on net assets which (at the time of writing) varies between 0.01% and 0.06% depending on the type of fund. In June, 2004, the Luxembourg government announced that pension funds would be exempt from the 0.01% ‘subscription’ tax, in order to encourage the transnational pooling of pensions assets.” (Lowtax.net).
Lowtax further reports: “In 2004, the Luxembourg authorities passed legislation creating a new form, the Societe d?Investissement en Capital A Risque (SICAR) which is intended to offer an alternative to the traditional limited partnership structure which works well for fund managers and investors in countries such as the United Kingdom, but can pose problems for fund managers in continental Europe.” (Lowtax.net). SICARs are catering to the needs of private equity firms.
The OECD emphasized another part of Luxemburg’s financial centre: “The financial centre is specialised in the management of interbank liquidity for international cross–border banks and asset management activities. The global financial crisis has had a strong impact on the financial sector with a substantial contraction of banks’ balance sheets, mostly related to lower interbank lending, and a fall in the value of assets under management due to the drop in equity prices. Two large cross – border banks came under severe pressure and were supported by the authorities in Luxembourg and their home countries, while three small subsidiaries of foreign banks were put into administration.” (OECD weblink).
In 2011, the IMF provided the following details on the role of Luxembourg’s banks: “Luxembourg’s banks are mostly foreign-owned and net providers of liquidity to their parent groups. […] The majority of these groups operate through both subsidiaries and branches in Luxembourg, which provides flexibility to accommodate clients’ needs for financial services and to optimize funding operations with parent groups. Indeed, reflecting the liquidity generated by treasury management for institutional customers, as well as private banking and custody activities, the local banking system is a net provider of liquidity to parent banks (‘upstreaming’). Overall, interbank positions represent about half of bank assets and liabilities (compared to an average of about 28 percent in the euro area), two thirds of these interbank positions are cross-border exposures, and intra-group exposures account for about 40 percent of total bank assets.” (IMF 2011: 8). Falk complements this view reporting that, according to the IMF, liquidity provided by Luxembourg is playing an important role for the financial stability of the Eurozone (Falk 2009: 15). During the recent crisis, money market funds from Luxembourg were reported to provide more than 100 bn. EUR in short term lending to banks. The global systemic risks stemming from Luxembourg’s key role in world financial markets (especially regarding the Eurozone) underlines the importance to keep and strengthen Luxembourg’s good reputation as a well managed financial centre (ibid.).
The strategic importance of Luxembourg’s financial centre is further explained by its role in securities settlement: “Luxembourg is also an international financial center for securities listing, and hosts systemically relevant market infrastructures. The main participants on the Luxembourg Stock Exchange (LSE) include large international banks, brokers, and investment funds. Activity on the LSE is driven by primary issuance, as Luxembourg accounts for about 15 percent of total bonds issued globally. Luxembourg also hosts Clearstream Banking Luxembourg (CBL), one of the two largest international ICSD [International Central Securities Depository] in the world, which has developed a strong position in international fixed income markets. A core part of CBL’s services offering is the settlement of transactions in international securities and domestic securities traded across borders. CBL also manages, safe keeps, and administers securities on behalf of its customers (i.e., more than 1,200 financial institutions in about 110 countries), and has developed services for collateral management and investment funds. As large amounts of collateral are involved in these activities, the operational and financial soundness of CBL is of relevance to international financial stability.” (IMF 2011: 9).
The influence exercised by the financial services industry on the political processes in Luxembourg and the degree of state capture is probably unparalleled. After the removal of a critical study on Luxembourg’s financial centre in 2009 (TJN-Blog), another instance of this is found in the recent IMF assessment published about Luxembourg. It stated: “The current legal framework does not sufficiently guarantee the full operational independence of the CSSF [Financial Sector Surveillance Commission]: the CSSF is placed under the direct authority of the Minister; its missions include the ‘orderly expansion’ of Luxembourg’s financial center; its general policy and budget are decided by a Board whose members are all appointed by the government upon proposals from supervised entities and the Minister; its executives are appointed by the government and can be dismissed in cases of disagreement about policy or execution of the CSSF’s remit; and its statute confines the executives’ role to elaborating measures and taking decisions required to accomplish its missions.” (IMF 2011: 20; [TJN-note]). Perhaps as a response to this, there has been a complaint about the degree of independence and integrity of the CSSF filed by trade unions, a consumer protection association, and an association of defenders of investor rights (L’essentiel online).
In contrast to the systemic importance of Luxembourg’s financial system, the assessment of Luxembourg’s anti-money laundering regime 2010 had a devastating result. Out of 49 assessed criteria, only one has been rated as compliant, nine as largely compliant, 30 as partially compliant, and nine as non-compliant (FATF 2010, V2: 261-277). Furthermore, those recommendations which can be seen as highly relevant to prevent the layering and integration of criminal funds through the financial system have been rated as deficient. These comprise recommendation 5 on customer due diligence (partially compliant), recommendation 7 on correspondent banking (non-compliant), recommendations 15 and 23 on internal controls, compliance and supervision (partially compliant), recommendations 16 and 24 on company service providers and other non-banks (non-compliant), and special recommendation 7 on wire transfer (partially compliant).
An important extension of Luxembourg’s role as secrecy jurisdiction can be seen in the formal introduction of trusts in Luxembourg law. The FATF details that in 2003, the Hague Convention on the recognition of trusts came into force: “La fiducie a été introduite en droit luxembourgeois par les articles 4 à 9 de la loi du 27 juillet 2003 – portant approbation de la Convention de la Haye du 1er juillet relative à la loi applicable au trust et à sa reconnaissance; […]” (FATF 2010, V2: 33).
This points to Luxembourgs important role serving as an interface for criminal money from around the world and the onshore economies of Western Europe. This view is broadly mirrored by a French investigating magistrate Renaud van Ruymbeke in 2010 (SZ). Similarly, Falk (2009: 17) mentioned a memorandum dating from 2006 to the Dutch Finance ministry concerning the attractiveness of money laundering which ranked Luxembourg first. Luxembourg is said to having even more advantages than a traditional tax haven because it unites advantanges of traditional onshore places (by being located in the heart of Europe), with offshore features (offering foreign companies and people advantages similar to those offered by a traditional tax haven). This “interface” role could explain why in Luxembourg reknowned banks exist alongside many financial firms with seat in exotic tax havens (ibid.: 10). Many letterbox companies are found in the registry which have their main seat in unambigious tax havens, including from Panama, British Virgin Islands, Seychelles, Gibraltar, Cayman Islands, Bermuda, Anguilla, Bahrain and Bahamas (ibid.: 18).
This view can be further corroborated by the legal framework governing companies registered in Luxembourg. As Atoz pointed out in 2009 (page 15), an independent auditor is not required for companies below a very generous threshold: “an independent auditor is required by law if 2 of the following 3 criteria are fulfilled by the company during two successive years: ­ total balance sheet: exceeds EUR 3,125 million; ­ net turnover: exceeds EUR 6,25 million; – average number of employees: exceeds 50. Below the threshold, a “statutory auditor” is required who can be anybody, including a shareholder of the company concerned (ibid.). There are indications that in practice individuals often set up different companies with similar business purposes in order to remain below the threshold and to avoid the need for an independent auditor.
A particular quality of Luxembourg’s anti-money laundering system is the fact that it goes out of its way to ensure that no piece of evidence can be used in tax investigations abroad: “The Law of 8 August 2000 on co-operation in criminal matters does not allow co-operation on accessory fiscal issues and, generally, the data exchanged may not be used for tax purposes, even accessory ones.” (FATF 2010, V1: 29). In addition, Luxembourg professionals may not even be allowed to report suspicious activity that may involve fiscal issues: “It is unclear whether professionals are in practice authorised to report transactions that might involve tax offences that are not predicate offences to ML.” (ibid.: 22). Furthermore, the FATF identified serious weaknesses in the reporting system for suspicious activity: “The number of STRs is very low, distributed among a small number of reporters, and the statistics show that many STRs are motivated not by suspicion but by the fact that the customer has been investigated or convicted.” (FATF 2010, V1: 22). A specialty in the corporate law is seen by the FATF as particularly inviting money laundering: nominal shares of joint stock companies can be transformed into bearer shares (FATF 2010, V2: 228).
Referring to exchange of information, “A new EU Council Directive on Administrative Cooperation in the Field of Direct Taxation, consistent with the international standard on transparency and exchange of information, was adopted by the Council of the European Union on 15 February 2011 and will come into effect on 1 January 2013. Upon its entry into force, this text will allow Luxembourg to exchange information in accordance with the standard with 15 more jurisdictions” (GF 2011: 16).
With respect to the historical developments and low tax specialties, Lowtax.net reports: “The development of the Euromarkets in the 1970s saw the emergence of Luxembourg as a successful international financial centre, and the country is now the world’s seventh largest such centre. Workers in the financial services sector make up around 11% of the total population, and the sector accounts for more than 40% of GDP, as well as generating the same proportion of the government’s tax receipts. Apart from the Stock Exchange, on which most Eurobonds are listed, there is a well-developed commercial and private banking sector, and Europe’s biggest investment fund industry. Much of this growth has been due to the availability of suitable ‘low tax’ or ‘offshore’ forms and structures alongside the normal economy.” (Lowtax.net).
Another comment puts Luxembourg’s financial sector in a context of increasing competition and pressure: “The Grand Duchy of Luxembourg has long been considered a de facto ‘tax haven’ by many continental Europeans. However, its membership of the European Union could threaten the jurisdictions ability to maintain banking and corporate confidentiality in the future. […] Luxembourg is still a major weapon in the tax planners arsenal but will find increasing competition from countries such as Malta and Cyprus.” (Budget Company Formations).
For many years, one of the main low-tax and secrecy attractions of Luxembourg were so-called 1929 Holding companies: “The statute from 31 July 1929 defines a holding company as follows: ‘A holding company is considered any and every Luxembourg-based company – the exclusive purpose of which is the acquisition of holdings, in any form, in other Luxembourgian or foreign companies, and in the management as well as the utilisation of these holdings, so that the company does not, of its own accord, undertake any industrial activity and/or maintain any sales-and-marketing branch office open to the public.’ […] The holding companies to which the ‘1929’ status applies pay an annual subscription tax (in the amount of 0.2% of their share capital). Otherwise, they are exempt from all taxes. […] On 19 July 2006, the European Commission pronounced the tax exemption for the ‘Holding 1929’ unlawful. According to this pronouncement, new establishments of companies in this form are no longer permissible. Any already-existing holding companies are entitled to a transition phase until 31 December 2010.” (LCG).
In 1990, Luxembourg introduced a type of company to allow allow holding companies to make use of Luxembourg’s growing treaty network: “[…] a Grand-Ducal decree of 24th December 1990 created a further type of holding company, the SOPARFI or Societe de participation financiere, which is within the normal Luxembourg corporate tax net but can receive dividends which are exempt from tax, and which can take advantage of the country’s double tax treaties (which the 1929 holding companies cannot).
As from 2007, the replacement for the 1929 holding company is the Family Private Assets Management Company, or SPF. These new vehicles are prohibited from commercial activity, and will be limited to private wealth management activity, for example the holding of financial instruments such as shares, bonds and other debt instruments, in addition to cash and other types of bankable asset. If the SPF is used to hold voting rights in other companies, it must ensure that it does not involve itself in the running of those companies, and it is prohibited from providing any kind of service.” (Lowtax.net).
Furthermore, it appears that no spontaneous information regarding these SPF can take place: “Control and supervision of the SPF: Only the Administration del ?Enregistreme? is qualified. This administration is different from the Tax authorities. Control is strictly limited to the respect of the conditions of the SPF Regime. No spontaneous or no information communication can be carried out by this administration except in the event of non-respect of the obligations of the SPF itself.” (Fidomes).
On ‘Black-Lists’ of
32 International Bureau of Fiscal Documentation 1977 Yes [Notes]
33 Charles Irish 1982 No [Notes]
34 Hines Rice 1994 Yes [Notes]
35 IMF 2000 No [Notes]
36 OECD 2000 Yes [Notes]
37 FSF 2000 Yes [Notes]
38 FATF 2000 / 2002 No [Notes]
39 Tax Justice Network 2005 Yes [Notes]
40 Zoromé 2007 (IMF) Yes [Notes]
41 Stop Tax Havens Act (USA) 2007 Yes [Notes]
42 Lowtax.net 2008 Yes [Notes]
43 OECD April 2009 Yes [Notes]
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