Personal income tax across jurisdictions: coordination of income tax treatment between country of residence, country of source and country of citizenship. For Luxembourg residents, calibration between the progressive income tax scale (up to 42 % marginal rate plus solidarity surcharge) and available exemptions. For cross-border situations, mapping of treaty provisions to eliminate double taxation on employment income, investment income and pension distributions.

Net wealth tax: Luxembourg levies a net wealth tax (impôt sur la fortune) on individuals and companies. For individuals, the first €500,000 of net wealth is exempt. For holding structures (SOPARFI, SPF), the minimum net wealth tax ranges from €535 to €32,100 depending on the balance sheet. We evaluate the global wealth tax exposure across jurisdictions — including France’s IFI for clients retaining French real estate, Italy’s IVIE for Italian residents holding foreign property, and Switzerland’s cantonal wealth taxes — and structure ownership to minimise the aggregate burden.

Capital gains — financial and real estate: in Luxembourg, gains on the disposal of a substantial participation (more than 10 % held for more than six months) are taxable at half the global rate, while gains on securities held for less than six months are taxed as speculative income. Through a SOPARFI, qualifying participations benefit from the participation exemption, rendering gains entirely exempt. For real estate, gains are taxable if the property is sold within two years of acquisition; beyond that, a tapering relief applies. We coordinate the capital gains treatment across the seller’s residence, the asset’s location and the holding structure’s jurisdiction to identify the most efficient disposal route.

Succession and estate planning: Luxembourg does not levy inheritance tax on transfers between direct-line heirs and spouses. For assets located outside Luxembourg, the applicable succession regime depends on the situs rule and the deceased’s last habitual residence under EU Regulation 650/2012 (Brussels IV). We map the inheritance tax exposure across all relevant jurisdictions — France (progressive rates up to 45 %, with €100,000 abatement per child every fifteen years), Italy (4 % above €1 million per heir in direct line), United Kingdom (40 % above £325,000) — and design anticipatory structures: donations, usufruct arrangements, trusts and family pacts to reduce the aggregate succession cost.

Life insurance and capitalisation contracts: Luxembourg’s life insurance regime offers a unique combination of investor protection (the “triangle of security” with segregated assets held by an approved custodian under CSSF supervision), multi-currency flexibility, and favourable tax treatment in many countries of residence. We advise on policy structuring, beneficiary clause drafting, and the interaction between the Luxembourg policy and the tax regime of the policyholder’s country of residence — particularly the French régime dérogatoire (Articles 757 B and 990 I CGI) for clients retaining French tax ties.

Corporate and holding structures: Luxembourg offers a comprehensive toolkit for wealth structuring: the SOPARFI for operational holdings with participation exemption and extensive treaty access, the SPF for passive family wealth management exempt from corporate income tax, and the SCSp for fiscally transparent co-investment vehicles. We design the corporate architecture to optimise the interaction between the structure’s taxation and the owner’s personal tax position, including dividend distribution policy, cash pooling arrangements and intellectual property routing.

International and cross-border tax coordination: bilateral tax treaties, exit tax provisions (including France’s exit tax under Article 167 bis CGI and Italy’s under Article 166 TUIR), impatriation regimes (Luxembourg Article 115-13a LIR, Italy’s regime for inbound workers under Article 16 D.Lgs. 147/2015), tax credits, elimination of double taxation, and fiscal coordination for multi-resident families and wealth distributed across several jurisdictions.