Guide
Luxembourg holding company owning a UK company: key points
Holding a UK company through a Luxembourg holding company calls for several checks before set-up. Here is the checklist we follow.
Points to check
- The conditions for holding the subsidiary (threshold and period) for the exemption regime.
- The level of taxation of the UK subsidiary.
- Withholding taxes and the tax treaty between Luxembourg and the United Kingdom.
- Effective management of the holding company, and its substance in Luxembourg.
- Filings at Companies House on the UK side and at the LBR on the Luxembourg side.
Roles in the structure
The roles of officer, accountant and supervisor should stay separate from each other, for independence and clarity of the file.
What we do
We coordinate the set-up with your tax advisers, administer the holding company and track the filings. The tax analysis is carried out by an authorised adviser.
Frequently asked questions
Does Brexit change the analysis?
Yes. European rules no longer apply to the United Kingdom in the same way. The analysis now rests on Luxembourg law and the bilateral treaty.
Must the holding have an officer in Luxembourg?
Effective management is a question of substance. We look at it at the design stage.
Let's talk about your structure.
Describe your situation. We reply with a first view of the way forward.