Domiciliation Services Luxembourg

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Law-Firm Domiciliation with Integrated Tax Counsel

Under Article 1 of the Luxembourg Domiciliation Law, only members of regulated professions — including attorneys-at-law — may act as domiciliation agent. WVT's position as a law firm places it in this category, enabling the firm to combine a CSSF-compliant registered office with the legal and tax advisory required to sustain the structure's treaty position and governance framework. For Luxembourg SOPARFI entities and intragroup financing vehicles, domiciliation without integrated substance assessment creates exposure under ATAD 3 and risks denial of Luxembourg's participation exemption and treaty network access. WVT advises on substance, beneficial ownership documentation and CSSF obligations as part of the domiciliation engagement from the outset.

Our expertise

Luxembourg SOPARFI holding companies, RAIF and SIF fund structures, and SPV financing vehicles operated by multinational groups and PE managers require a domiciliation agent that can advise on treaty access, ATAD 3 exposure, CSSF obligations and fund governance — not merely administer a registered address. WVT provides all of this within a single mandate.

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ATAD 3, Substance and Treaty Access for Luxembourg Entities

Luxembourg SOPARFI and financing entities that receive dividends, interest or royalties from cross-border group structures face increasing scrutiny under ATAD 3 and the EU Anti-Tax Avoidance Directives. Entities identified as lacking genuine economic substance — no exclusive premises, no active bank account, no qualifying substance factor — risk denial of Luxembourg's treaty benefits and mandatory exchange of information with source-country tax authorities. WVT assesses each Luxembourg entity's substance position at the point of domiciliation and on an ongoing basis, identifying gaps in director residency, meeting frequency and documentation before they become a regulatory exposure. Where advance certainty is required, WVT coordinates applications for Luxembourg tax rulings to confirm the entity's treaty eligibility and substance position with the Administration des contributions directes.

FAQ's

Who is authorised to act as a domiciliation agent under Luxembourg law?

The Luxembourg Law of 31 May 1999 restricts the activity of domiciliation agent to members of specific regulated professions: credit institutions and other financial sector professionals, attorneys-at-law practising under their home-country title, company auditors, approved auditors, and chartered accountants registered with the Ordre des Experts-Comptables. WVT qualifies as a domiciliation agent in its capacity as a law firm, and provides domiciliation within its regulated legal and tax practice.

What must a Luxembourg domiciliation agreement contain?

Under the Law of 31 May 1999 and the applicable CSSF circular, a domiciliation agreement must identify the domiciled company and its beneficial owner, set out the services to be provided by the domiciliation agent, confirm the agent’s AML/CTF obligations, and be signed by both parties before the company establishes its registered office at the agent’s address. WVT prepares compliant domiciliation agreements as a standard element of each engagement, coordinated with the required beneficial owner identification process.

Can a Luxembourg SOPARFI be domiciled without maintaining physical premises?

A SOPARFI or other holding vehicle that does not conduct commercial activities requiring an establishment permit may be domiciled at the address of a regulated domiciliation agent without maintaining its own physical premises. However, domiciliation alone does not satisfy the substance requirements necessary to access Luxembourg’s participation exemption, treaty benefits, or EU Directive protections. WVT advises on the governance and substance measures required to support those benefits alongside the domiciliation engagement.

How does ATAD 3 affect Luxembourg domiciled holding companies?

ATAD 3 targets entities that receive predominantly passive income — dividends, interest, royalties — and lack genuine economic substance, identifying them as shell companies subject to denial of treaty benefits and mandatory exchange of information. Luxembourg SOPARFI and financing entities domiciled without adequate resident directors, qualifying premises or documented decision-making are at risk. WVT assesses each entity against the three minimum substance indicators defined under ATAD 3 and advises on corrective measures before regulatory scrutiny arises.

Does WVT provide domiciliation for RAIF and SIF structures?

WVT provides regulated domiciliation for Reserved Alternative Investment Funds, Specialised Investment Funds and SICARs under the Luxembourg Law of 31 May 1999. For fund structures, domiciliation is coordinated with the fund’s AIFM appointment, CSSF registration obligations and ongoing governance requirements. WVT advises on the interaction between the fund’s Luxembourg substance requirements, the domiciliation framework and the AIFM’s regulatory obligations as part of a single integrated mandate.