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Convention for the Avoidance of Double Taxation, Holding Luxembourg & HK

Asked in Offshore (General) for Luxembourg

Hi, i start a new thread about the convention for the avoidance of double Taxation between the Luxembourg and Hongkong.

I would like to know if this convention, can help me on my project.

I would like to make a Luxembourg company, with HK holding.
The HK company do get approx 60% of share capital about the Luxembourg company.

My question, is, at the end of year, the HK company can get the 60% of dividend, before taxation in Luxembourg ?
Exemple : 100 Euros of dividend, 60Euros go to HK company, without Luxembourg taxation.

Or Luxembourg taxation do get approx 29% of this 60Euros, before send the dividend to HK company ?

At the reverse, if i not really understand, maybe the best is Luxembourg company get 60% of Hongkong company, and Luxembourg no make taxation on the dividend received from HK company.

Thank you for your answer, and help !
Luxembourg Tax Tax
Posted by Franck on Feb 26, 2012 at 17:44


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Dear Franck,

Honk kong -> Luxco is very a good solution to distribute a dividende.
From the Grand-Ducal regulation of 18 december 1998: The conditions for the beneficiary (Honk Kong Company) if it does not satisfiy the detention period 12 months from the date of distributes of dividends but if HK Company agrees to hold more than 12 months. For your, end of year 2012, LuxCo will pay an interim dividen. Luxco will pay a withholding tax (15%) and when the HK hold 12 12 months the tax authorities Lux reimburses the withholding tax.
Now, there's an another solution. I suppose 1/04/2012 HK incorporate Luxco or HK buy 60% on Luxco: end of year 2012, Luxco will take a loan (with interests) to HK example EUR 100.000,00. The 2/04/2013 the general meeting of shareholders resolved to pay a dividend of EUR 200.000,00. The general meeting of shareholders will decide to pay the dividend (for HK) one part in cancellation of the loan made in 2012 (EUR 100.000,00) andthe rest in cash EUR 20 000 (200 000 * 0.60= 120 000 - 100 000).
I hope is clear. for more information please my email:
kind regards,
Posted by Lowtax User on Feb 27, 2012 at 20:31


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best speak to a tax adviser. dividends in luxembourg are not tax efficient. Look at loans instead
Posted by Lowtax User on Oct 08, 2013 at 06:41


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