Substance Requirements Luxembourg - Directors & Office | LuxLex Law

Substance Requirements Luxembourg

Ensure your Luxembourg company meets substance requirements. Director services, registered office, personnel, and ATAD compliance.

8 min read Updated: Décembre 2025

In summary: Luxembourg substance requirements include: qualified directors (typically 2+), physical office presence, local decision-making, qualified personnel, and genuine economic activity. Proper substance is essential for tax treaty benefits and EU directive application.

Economic Substance in Luxembourg

Economic substance is a critical consideration for companies established in Luxembourg. International tax standards, EU directives, and Luxembourg tax law all require companies to have genuine economic presence to benefit from the country's tax advantages.

Key Substance Elements

Board of Directors

The composition and conduct of the board is central to demonstrating substance. Directors should have appropriate qualifications and actively manage the company.

Requirement Best Practice
Number of directors Minimum 2 qualified directors
Residency Majority Luxembourg/EU resident
Qualifications Relevant industry/financial experience
Meetings Regular board meetings in Luxembourg
Decision-making Strategic decisions made in Luxembourg
Availability Directors available for urgent matters

Physical Presence

  • Registered office: Official address for legal correspondence
  • Office space: Dedicated premises for business activities
  • Meeting rooms: Facilities for board meetings
  • IT infrastructure: Proper systems and data management
  • Bank accounts: Local banking relationships

Personnel

Qualified employees in Luxembourg demonstrate genuine economic activity. The level of staffing depends on the company's activities and complexity.

Role Function
Compliance Officer Regulatory compliance and AML
Finance/Accounting Financial management and reporting
Investment Management Portfolio monitoring (for holding companies)
Administration Corporate secretarial functions

Regulatory Requirements

ATAD (Anti-Tax Avoidance Directive)

ATAD requires substance for companies to benefit from intra-group arrangements. Key provisions include:

  • General Anti-Abuse Rule (GAAR)
  • Interest limitation rules
  • Exit taxation
  • CFC rules for passive income

Tax Treaty Benefits

To access Luxembourg's 103 tax treaties, companies must demonstrate:

  • Beneficial ownership of income
  • Not being a conduit company
  • Principal Purpose Test (PPT) compliance
  • Genuine economic activity

Substance Documentation

Evidence to Maintain

  • Board meeting minutes held in Luxembourg
  • Signed resolutions and decisions
  • Employment contracts for Luxembourg staff
  • Office lease agreements
  • Bank statements showing local operations
  • IT and infrastructure evidence
  • Travel records of directors
  • Time allocation records

Our Services

  • Director services: Experienced professionals for your board
  • Registered office: Premium office locations in Luxembourg
  • Substance assessment: Evaluation of current substance level
  • Compliance monitoring: Ongoing substance maintenance
  • Personnel solutions: Staffing and secondment arrangements
  • Documentation: Corporate governance and record-keeping

Frequently Asked Questions

Substance refers to the economic presence of a company in Luxembourg: qualified directors, local employees, decision-making in Luxembourg, physical office, and real economic activities. It is essential to benefit from tax treaties and avoid requalification as a conduit company.

Find Your Lawyer

Describe your project and we will connect you with a qualified lawyer.

  • Free referral
  • Response within 24 hours
  • Verified lawyers

Request a Consultation

* Required fields. We typically respond within 24 hours.