Audit Royal S.A. | About us, Tax environment, Tax consultancy, Holding companies anf more .

Taxengineering.com


	Audit Royal SA was founded in 1988 and TaxEngineering.com was set up in 2001 as a specialist cross border tax treaty service for multinational and family businesses, especially in relation to Holding Companies. Luxembourg is a very good place to be centralised. It has a reasonable Tax approach and it is multilingual. TaxEngineering.com work with specialist Tax firms both in Luxembourg and around the world. Emphasis is put on working with all EU countries, Iceland , Switzerland , Russia , Kazakhstan , Mexico and China as well as New Zealand and Hong Kong .


	TaxEngineering.com have as their main objective to advise on the accumulation of tax free profits for Re-investment through the use of tax treaties. Ultimately tax will usually be payable, other than in countries that have no tax. In any event our philosophy is: "It is better to pay a little tax rather than no tax."



	The EU and the OECD, since 1996, have clearly made " tax harmonisation" one of their priority objectives. This means that " tax fraud" is going to be treated much more like "money laundering". There will be exchange of information between tax havens and high tax countries. Bank secrecy in relation to "tax fraud" will slowly disappear. In any event professional advisors, banks and insurance companies must know clearly who their clients are and the business they do. The way forward is to use tax treaties. " It is better to pay a little tax rather than no tax" and transparency.


	Audit Royal S.A. have always been cross border tax specialists, working with colleagues, tax lawyers and accountants all around the world. Not only do Audit Royal S.A. advise on tax structures they will also coordinate the constitution and administration of appropriate tax advantageous entities and companies, virtually anywhere in the world.


	Luxembourg being a crossroads between France, Germany and Belgium and having a very strong international reputation in banking and investment, is an ideal location in Europe to centralise cross border tax consultancy. Luxembourg's strength is also its language ability. Not only do most people speak French, German, Luxemburgish and English there are also strong local communities who speak Portuguese and Italian. Audit Royal S.A. has all these languages plus Spanish and Russian.


	Luxembourg is well known as a centre for Holding companies. Conforming to the EU’s Parent/subsidiary Directive Luxembourg’s “Soparfi” financial holding company also benefits from Luxembourg’s impressive array of double tax treaties. The main advantage of a luxembourg “Soparfi” is where a participation is made (subject to certain rules) representing more than 10% in another company for more than one year; the effect can be no tax on dividends received or on capital gains. The Luxembourg Soparfi benefits from the EU Directive on both receipts and payments of interest and Royalties. In addition Luxembourg has no withholding taxes on payments of Interest and Royalties to countries outside the EU In addition, for as long as it lasts, Luxembourg has its “1929 Holding company”, which is not subject to tax and does not normally benefit from Luxembourg tax treaties. This company has the advantage that it can very easily be transformed into a “Soparfi”. Or Vice Versa, if more than 5% of Dividends come from Offshore the 1929 Holding will be taxable like a Soparfi . Luxembourg is not the only country with tax advantageous holding companies. Belgium, Germany, Spain, Hungary, Malta, Cyprus, Mauritius and the UK are all countries, amongst others, that offer tax advantages.