Tax ruling: prior ACD agreement in Luxembourg
Fully secure the tax treatment of your operations
A tax ruling is a formal position of the Luxembourg tax authority (ACD) on the tax treatment of a planned operation. It provides complete legal certainty for a defined period, enforceable against the administration.
Key metrics
Our tax experts help you structure your optimization in strict compliance with Luxembourg law and OECD/BEPS standards.
Talk to a tax expertKey advantages
- Full legal certainty on planned tax treatment
- Enforceability against ACD during validity period
- Clarification of complex tax grey zones
- Reassures investors, bankers and auditors
- Allows presentation of a stabilized business plan
- Covers notably: transfer pricing, substance, income qualification
Qualifying conditions
- Planned operation (not yet executed) or prospective structure
- Written and motivated request to ACD
- Complete description of facts and legal framework
- Substantiated tax analysis by advisor
- Administrative fees: EUR 3,000 to EUR 10,000 depending on complexity
- Demonstrated economic substance
Who this regime is for
Securing an IP Box structure for a biotech
A Luxembourg biotech wishes to apply the IP Box regime to its patents. The Nexus calculation is complex (internal R&D + partner subcontracting).
Risk of later reassessment
5-year legal certainty
EUR 10M
The ruling formally validates the retained Nexus methodology, R&D expense qualification and patent eligibility. The company can then present its accounts with full confidence to investors and auditors, without risk of tax reclassification.
Legal basis and OECD compliance
OECD framework and transparency
Since BEPS Action 5, Luxembourg rulings are subject to automatic information exchange with concerned jurisdictions. ACD no longer issues rulings on regimes deemed harmful. The current regime fully complies with OECD transparency standards.
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The faces behind
Bookkeeper.lu
A Luxembourg-based team dedicated to the success of your entrepreneurial project.
Mickaël LOC
17 years at the heart of Luxembourg structures.
Managing Director of Financial Services Luxembourg, Mickaël supports entrepreneurs, SMEs and family offices in structuring, creating and managing their Luxembourg entities. Recognized expert, cited in Le Figaro.
No. AE 0/10077274
Business authorization
17 years experience
Lux. corporate law
Cited in Le Figaro
Recognized expertise
FR · EN · DE · LU
Multilingual advisory
Antoine MARCHI
Technology at the service of fiduciary.
Architect and developer of the Bookkeeper.lu platform, Antoine designs the automation, AI and cloud infrastructure tools that enable Financial Services to deliver a fast and reliable digital service.
5+ years experience
Software Engineering
AI & Automation
Cloud, DevOps, Full-stack
Product Builder
Fintech & SaaS
Next.js · React · TypeScript
Modern stack
Our values
Responsiveness
Guaranteed response within 48 hours. We handle every request with the utmost urgency.
Client satisfaction
Your success is our top priority. 98% of our clients recommend us.
AI-powered execution speed
Thanks to artificial intelligence, we accelerate every step, from drafting articles of association to full accounting management.
Made in Luxembourg
Everything is done from Luxembourg. Local team, data hosted in Europe, guaranteed compliance.
Other optimization regimes
Explore the other Luxembourg tax mechanisms available.
SOPARFI
Most usedArt. 166 LIRThe most widely used Luxembourg holding vehicle in Europe
IP Box
Art. 50ter LIREffective rate of about 5% on intellectual property income
Fiscal unity
Art. 164bis LIRConsolidate a group fiscally and offset losses between entities
Tax treaties
OECD model and bilateral agreementsOver 80 treaties to avoid double taxation
RAIF
Law of 23 July 2016Fast and flexible structuring for well-informed investors
Frequently asked questions
How long is a tax ruling valid?
Standard validity is 5 years, provided facts and legal framework remain unchanged. Renewal may be requested at the end of the period. ACD may revoke the ruling in case of substantial legislative change.
What are the administrative fees?
Fees range from EUR 3,000 to EUR 10,000 depending on complexity (amount set by ACD at filing). Tax advisory fees are added (generally EUR 10,000 to EUR 50,000 for a structuring file).
Is a refused ruling enforceable against the company?
No. A refusal or unfavorable response does not bind the company. It may adjust its structuring or abandon the operation. The ruling is only enforceable against ACD if favorable and applied in accordance with described facts.
Is the ruling confidential?
Partially. Content remains confidential vis-à-vis third parties, but since BEPS Action 5, an anonymized summary is automatically exchanged with tax administrations of concerned jurisdictions (DAC 3 directive).
Optimize your tax structure
Our experts analyze your situation and design the tax structure best suited to your objectives, in full compliance.