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- 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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more
- New taxation regime for the revenue of some
intellectual property rights
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more
- New IP exemption regime - How to deal
with the affiliation requirements set out by the Law ?
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more
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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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