Many companies are looking into moving their registered office from their countries like Cayman, BVI, Cyprus, Bermuda, channel islands… to Luxembourg due to changes in political, economical or legal framework.
Some managers are willing to close their fund and establish them in a more transparent jurisdiction.
But other managers want to keep their track record, avoid exchanges of shares or redemption by their shareholders.
In order to become an entity duly incorporated under Luxembourg laws, a foreign company or fund established abroad may simply elect to transfer its seat, change its nationality and redomicile to Luxembourg.
When a foreign company transfers its registered office or seat or its main place of management in Luxembourg, it will sever the links with its country of first incorporation unless it keeps a permanent establishment there.
Hence the company will not be taxable in its former country of incorporation but will become taxable on its worldwide income in Luxembourg.
Furthermore, it will be considered as resident for tax purposes. It will benefit from the network of double tax treaties and will become a subject to tax in luxembourg at the applicable corporation tax rates
– unless its shareholders elect for a favorable tax regime in Luxembourg which grants a specific tax exemption such as the SOPARFI (Holding Company), RAIF, SIF, SICAV or the SPF (Private Wealth Management Company)
Creatrust provides a one-stop-shop service for the setup and administration of Corporate, Fund and Family Office vehicles based in Luxembourg. For more information please visit our specific web pages:
Corporate: https://www.creatrust.com/corporate-clients
Fund: https://www.creatrust.com/investments-funds
Family Office: https://www.creatrust.com/family-offices
Or contact us here or by emailing info@creatrust.com.
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