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Law-Firm Domiciliation with Integrated Tax Counsel

In Luxembourg, only members of regulated professions — including attorneys-at-law — may act as domiciliation agent under the Law of 31 May 1999. WVT qualifies in that capacity and provides CSSF-compliant domiciliation for SOPARFI, RAIF, SIF and SPV structures, including beneficial owner identification, domiciliation agreements and corporate document custody. In Switzerland, WVT provides registered office services for Swiss AG and GmbH holding and IP structures alongside substance advisory under the Anti-Abuse Decree 1962, resident director coordination, and cantonal tax ruling applications — ensuring each engagement is structured to withstand ESTV scrutiny from inception.

Our expertise

Cross-border holding structures, fund vehicles and IP licensing entities across Luxembourg and Switzerland require a domiciliation agent with the legal and tax standing to advise on substance, treaty access, CSSF obligations and ESTV scrutiny — not merely administer a registered address. WVT provides all of this within a single mandate across both jurisdictions.

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Multi-Jurisdiction Substance Under One Mandate

Groups with holding layers spanning Luxembourg and Switzerland increasingly face coordinated substance scrutiny across both jurisdictions simultaneously. A deficit in one entity — insufficient resident directors, inadequate premises, absent documentation — can trigger treaty benefit denial and exchange of information with source-country tax authorities across the entire structure. WVT coordinates substance reviews across Luxembourg and Switzerland 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 — including CSSF-compliant governance records in Luxembourg and ESTV-ready board meeting evidence in Switzerland.

FAQ's

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

In Luxembourg, the Law of 31 May 1999 restricts the domiciliation agent role to members of regulated professions, including attorneys-at-law, financial sector professionals, company auditors and chartered accountants. WVT qualifies as an attorney-at-law in that capacity. In Switzerland, no equivalent licensing law applies, but Swiss law requires at least one director of a Swiss AG or GmbH to be domiciled in Switzerland. WVT provides qualified resident directors and coordinates domiciliation in both jurisdictions within its regulated legal and tax practice.

What substance requirements apply to a Luxembourg SOPARFI or Swiss AG holding company?

In Luxembourg, SOPARFI entities accessing the participation exemption and EU Directive benefits must demonstrate genuine substance — exclusive premises, an active Luxembourg bank account, and a qualifying substance factor. In Switzerland, the ESTV applies a three-part test: personal substance, functional substance and financial substance. WVT advises on satisfaction of each set of criteria, prepares the required documentation, and coordinates the evidence trail needed to support treaty access in both jurisdictions.

How does ATAD 3 affect holding structures domiciled in Luxembourg or Switzerland?

ATAD 3 targets entities generating predominantly passive income — dividends, interest, royalties — that lack genuine economic substance. Entities deemed shell companies risk denial of treaty benefits, income attribution to the ultimate parent, and mandatory exchange of information with source-country tax authorities. WVT assesses Luxembourg and Swiss structures against the three minimum substance indicators defined under ATAD 3 and advises on corrective structuring where a structure is at risk, coordinating the review across both jurisdictions simultaneously.

Can WVT provide resident directors as part of a domiciliation engagement in both jurisdictions?

Resident director provision is available as part of WVT’s domiciliation engagement in both Luxembourg and Switzerland. In Luxembourg, directors with relevant professional knowledge support CSSF-compliant governance and satisfy the substance expectations of the Administration des contributions directes. In Switzerland, at least one Swiss-domiciled director with individual signing authority is a statutory requirement. WVT provides or coordinates qualified appointments in both jurisdictions, documented and integrated within the broader legal and tax mandate.

Does WVT coordinate cantonal tax rulings and Luxembourg tax rulings alongside domiciliation?

WVT coordinates tax ruling applications in both jurisdictions as part of the domiciliation mandate. In Luxembourg, rulings with the Administration des contributions directes provide advance certainty on the SOPARFI’s participation exemption eligibility and treaty position. In Switzerland, cantonal ruling applications — filed with Zug, Zurich or Geneva depending on the entity’s registered seat — confirm holding income treatment and treaty access. WVT prepares the substantive submission and manages authority correspondence in both jurisdictions throughout.