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Domiciliation Within a Legal and Tax Mandate

In the Netherlands, domiciliation for financing and licensing conduits carries statutory substance conditions that affect dividend withholding tax exemptions and treaty access. WVT's attorneys advise on those conditions as part of the domiciliation engagement — not as a separate instruction. In Luxembourg, only members of regulated professions may act as domiciliation agent under the Law of 31 May 1999. WVT qualifies as such and provides the full range of services required under that framework, including corporate document custody and correspondence management.

Our expertise

Cross-border holding structures, intragroup financing vehicles and regulated fund entities across the Netherlands, Luxembourg and Switzerland require more than a registered address — they require a domiciliation agent with the legal and tax standing to advise on substance, treaty position and regulatory compliance across all three jurisdictions simultaneously.

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Multi-Jurisdiction Substance Under One Mandate

Groups with holding layers spanning the Netherlands, Luxembourg and Switzerland increasingly face coordinated substance scrutiny across multiple jurisdictions simultaneously. A deficit identified in one entity — insufficient resident directors, inadequate premises, absent payroll — can trigger reclassification in source jurisdictions and deny treaty-based withholding exemptions on dividends or interest upstream. WVT coordinates substance reviews across all three jurisdictions within a single advisory mandate. Our attorneys and tax advisors identify gaps, implement corrective measures and prepare the documentation required to evidence genuine economic activity to tax authorities and, where applicable, to the CSSF.

FAQ's

What are the substance requirements for a Dutch holding or financing company?

Dutch financing and licensing conduits that benefit from tax treaty reductions or EU Directive exemptions must satisfy a set of statutory conditions, including resident directors with relevant expertise, qualifying office space, minimum payroll costs of EUR 100,000, and an active Dutch bank account. WVT advises on satisfaction of each criterion and prepares the annual confirmation required in the Dutch corporate income tax return.

Who is authorised to act as a domiciliation agent in Luxembourg?

Under the Luxembourg Law of 31 May 1999, only members of specific regulated professions — including attorneys-at-law and certain financial sector professionals — may act as domiciliation agent. WVT qualifies in that capacity and provides compliant domiciliation agreements, beneficial owner identification and the full suite of administrative services required under the CSSF circular applicable to professional financial sector domiciliation providers.

How does the ATAD 3 Unshell Directive affect holding structures in the Netherlands and Luxembourg?

ATAD 3 targets entities that generate predominantly passive income and lack genuine economic substance. Entities deemed to be shell companies may be denied treaty benefits, have income attributed to their ultimate parent, and face mandatory exchange of information between tax authorities. WVT assesses existing structures against the three minimum substance indicators — exclusive premises, active EU bank account, and a qualifying substance factor — and advises on restructuring where a structure is at risk.

Can WVT provide local directors as part of a domiciliation engagement?

Local director provision is available as part of WVT’s domiciliation service in the Netherlands, Luxembourg and Switzerland. Resident directors with relevant professional knowledge contribute to satisfaction of substance requirements in each jurisdiction and support the governance framework expected by local tax authorities and, in Luxembourg, the CSSF. Arrangements are documented and coordinated with the broader legal and tax advisory mandate.

Is a domiciliation address sufficient to establish tax residency in Luxembourg or the Netherlands?

A registered address alone does not determine tax residence. In both the Netherlands and Luxembourg, effective place of management — determined by where key decisions are made by directors with the appropriate knowledge and authority — is the primary factor. WVT structures domiciliation engagements to support a credible place of effective management, ensuring that the registered address is reinforced by documented governance, resident directors and substantive decision-making at the domicile.