Financial Accounting and Tax Services

  • Fiscalité des entreprises luxembourgeoises- Changements législatifs 2008-2009
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  • Transformation from a "Holding 1929" company to an SPF
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  • New taxation regime for the revenue of some intellectual property rights
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  • New IP exemption regime - How to deal with the affiliation requirements set out by the Law ?
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Services
 

Transformation from a "Holding 1929" company to an SPF

  • Transitional period from 1st January to 31 December 2010
  • Operations which lead to the loss of the status of a Holding 1929 company:
  • Full or partial sale (no defined threshold) of shares or units
  • Operations which do not result in the loss of the Holding 1929 status:
  • Transfer of the Holding 1929 company's registered office abroad
  • Partial liquidation (reimbursement of the initial contribution of a partner)
  • Possible to transform the company into an SPF if the shareholders are eligible
  • Corporate shareholders may declare that they are acting on behalf of natural persons within the scope of the management of their wealth (NB: domiciliary agent or independent auditor must certify the status of shareholders at least once per year)
  • Modification of the corporate object by decision of the general meeting before a notary: the name of the new company must contain "SPF" and the corporate object must exclude the application of the tax regime applicable to Holding 1929 companies and include the application of the tax regime applicable to SPFs

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