Luxembourg

Introduction

 

About Luxembourg

Luxembourg has the second highest GDP per capita in the world and its economy is largely dependent on banking, steel and industrial sectors. Given its centralised location in Europe, Luxembourg has leveraged on its connectivity to several other international markets and access to the European market to counter its small domestic market.

Finance remains the largest Luxembourgish economy driver, with the country specialising in cross-border fund administration business. An internationalised banking sector, a skilled labour force and accessibility to other European centres have further propelled Luxembourg's financial sector.

Business-friendly regulatory frameworks, competitive tax rates and RDI incentives have further incentivised foreign investment and innovation within the country. The government has offered subsidies to small-to-medium enterprises (SMEs) and tax exemptions for start-ups to increase entrepreneurship in the country. Moreover, due to the size of the country, public institutions have less bureaucratic structures which enhance the efficiency of administrative procedures.

Luxembourg is also one of the biggest financial centres in Europe, with 155 banking establishments. Capital markets remain relatively free, with minimal exchange controls.

 

What solutions are available in Luxembourg?

Solution Description
Treasury Centres A centralised treasury is one way to reduce the tax burden, centralise risk management, improve liquidity and enhance yield on cash.
Interest Optimisation Maximise your interest yield from for your balances held with the bank.
Notional Pooling Cash balances in different accounts are notionally offset to derive the net balance, which is then used to calculate interest.
Sweeping/ Zero Balance Account (ZBA) ZBA are checking accounts with zero balances where funds are physically swept to eliminate excess balances and maintain greater control over disbursements.
In-house Banks (IHB) In-house banks provide corporate treasurers with another method of centralising and consolidating their business.
Intercompany loans Similar to bank loans, intercompany loans refer to lending between entities within the same group.

Corporate Treasury in Luxembourg

Luxembourg is one of the wealthiest countries in Europe and is a founding member of the European Union. It has a highly developed financial services sector. Here, we highlight some of the key benefits relevant to treasury and cash management in Luxembourg.

 

Financial Market Development

  • The World Economic Forum ranks Luxembourg 11th in the world for financial market development in The Global Competitiveness Report 2015-2016.
  • It ranks Luxembourg 12th in the world for the soundness of its banks, while it comes second for both the availability and affordability of financial services. It rates it sixth for the ease of access to loans, eighth for venture capital and 16th for financing through local equity markets.
  • Luxembourg has excellent business infrastructure, an international and highly skilled labor force, an attractive legal framework and a stable macroeconomic environment.
  • There are no foreign-exchange controls in Luxembourg.

 

Sophistication of Banking Systems:

  • There are more than 150 banks operating in Luxembourg, of which 90% are foreign-owned. Among these, 111 are incorporated under Luxembourg law and 43 are branches of foreign banks.
  • Luxembourg is a key private banking centre in the Eurozone and the second-largest fund management center in the world.
  • Luxembourg's foreign-exchange market has an average daily turnover of USD 37 billion (Bank for International Settlements triennial global survey 2016).
  • Luxembourg has a well-developed debt market with both government and corporate bonds available. The government recently issued new bonds for the first time since 2013.

 

Regulatory Bodies

  • The banking industry is regulated by the Financial Sector Supervisory Authority. As a Eurozone country it is also covered by the Single Supervisory Mechanism. Luxembourg’s central bank is the Banque Centrale du Luxembourg.

 

Tax

  • The corporate income tax (CIT) rate was reduced to 19% for companies with a net taxable base of EUR 30,000 in 2017. It will be reduced to 18% in 2018.
  • Companies also pay a solidarity surtax on CIT of 7% and municipal business tax, which varies according to location and is charged at 6.75% in Luxembourg City, giving an overall tax rate of 27.08% for companies in Luxembourg City in 2017, falling to 26.01% in 2018.
  • Companies are subject to a net wealth tax of 0.5% on their net wealth on a taxable base of up to EUR 500 million and 0.05% on the component above this amount.
  • Resident companies pay tax on their worldwide income. Non-resident companies are taxed on income deriving from Luxembourg.
  • VAT is charged at a standard rate of 17%. Certain goods and services qualify for lower rates of 14%, 8% and 3% or are zero-rated. Banking and financial transactions are generally exempt.
  • There is no stamp duty in Luxembourg.
  • Dividend income is tax-exempt if the conditions of the 'participation exemption' regime are met.
  • Interest income is taxed as corporate income. Interest expenses are tax-deductible.
  • Tax incentives, usually in the form of investment tax credits, are available for companies in the areas of risk capital, audio-visual activities, environmental protection, R&D, professional training and the recruitment of unemployed people.
  • There is no withholding tax (WHT) on interest in Luxembourg. WHT on dividends is either 0% or 15% for resident companies. Non-resident companies pay a rate of 15%, unless a tax treaty is in place, then rates range from 0% to 25%.
  • Luxembourg has tax treaties with around 80 countries and territories.
  • Luxembourg is a signatory to the Organisation for Economic Co-operation and Development's Multilateral Competent Authority Agreement, through which information is exchanged between tax administrations, to provide a single, global picture on some key indicators of economic activity within multinational enterprises.

 

Benefits for Regional Treasury Centres

  • Luxembourg's stable tax, legal and regulatory regimes make it a highly popular location for companies to base their regional and worldwide treasury operations and shared service centers.
  • It offers access to a wide range of banking services and flexible structuring solutions, as well as an attractive tax regime, including the lowest VAT rate in Europe.
  • Cash concentration is available in Luxembourg. Different legal entities can participate in a notional cash-pooling structure in Luxembourg. There are no regulatory restrictions on cross-border sweeping, but there are central bank reporting requirements.
  • Notional pooling is available in Luxembourg on a domestic and cross-border basis. Multiple legal entities can participate in a notional cash-pooling structure.
  • Luxembourg is a member of the pan-European TARGET2 real-time gross settlement system.
  • It has an extensive tax treaty network.
  • Luxembourg is a Eurozone country with trading hours that overlap with Asia, Europe and North America.

 

Banking

 

Banking System

  • There are 146 authorised banks, of which 20 are domestic banks, 80 are foreign banks and 46 are branches of foreign banks.
  • Seven of Luxembourg's largest banks take up 35% of total banking assets. The largest bank in terms of assets is Deutsche Bank, followed by foreign and foreign private banks and two domestic banks, Banque et Caisse d'Épargne de L'État (BCEE) and Banque Internationale à Luxembourg (BIL).
  • Luxembourg provides a diverse range of banking services, particularly in private, asset-servicing, corporate and retail banking, and although it serves its domestic market, the vast majority of services are geared towards the international market through its foreign banks. It also provides services for country segments, such as asset servicing for US and UK banks, and asset servicing and private banking for Swiss banks.
  • Luxembourg operates a universal banking system, and three of its largest banks are universal banks.

 

Bank Accounts

  • Residents may hold foreign-exchange and domestic-currency accounts both domestically and overseas, whereby domestic-currency accounts are freely convertible to foreign currency.
  • Non-residents may hold foreign- and domestic-currency accounts, whereby domestic-currency accounts may be held overseas and are freely convertible to foreign currency.
  • Interest is available on current accounts.

 

Legal and Regulatory

  • Banque Centrale du Luxembourg (BCL) is an autonomous institution and a member of the European System of Central Banks (ESCB).
  • Commission de Surveillance du Secteur Financier (CSSF) regulates the banking sector.
  • The European Central Bank (ECB) supervises banks within the Eurozone that are regarded as 'significant' through the Single Supervisory Mechanism (SSM), and other 'less significant' banks are supervised by the national central bank. In the case of Luxembourg it is the banking regulator, CSSF.
  • There are no foreign-exchange controls in place.
  • Luxembourg is one of the founding members of the European Union (EU).
  • A company is resident if it has its head office in Luxembourg.
  • Luxembourg has anti-money laundering and counterterrorism financing legislation in place, and follows EU anti-money laundering directives.
  • Luxembourg has set up a financial intelligence unit, the Financial Cellule de Renseignement Financier (FIU-LUX), which is a member of the Egmont Group.
  • Individuals entering or leaving the EU are required to declare currency of EUR 10,000 to customs.

 

Payments

 

Payment Systems

TARGET2

The Eurozone's Real-time Gross Settlement (RTGS) system

  • Operates on behalf of the Eurosystem.
  • Three Eurosystem central banks – Banca d'Italia, Banque de France and Deutsche Bundesbank – provide the Single Shared Platform (SSP) of TARGET2.
  • Processes high-value and urgent EUR-denominated domestic and cross-border credit transfers.
  • Activates final settlement of participants' net balances from STEP2 (pan-European Automated Clearing House).
  • Settles transactions in real time and with immediate finality.
  • Transactions are processed electronically using SWIFT.
  • Final settlement is done across participant banks' correspondent accounts held at the SSP.
  • Luxembourg has 37 direct participants.

 

EURO1

Pan-European RTGS-equivalent net settlement system

  • Operated by EBA Clearings.
  • Processes high-value (no maximum value threshold) and urgent Euro-denominated domestic and cross-border payments.
  • Payments processed with immediate finality and are irrevocable.
  • 52 participant banks.

STEP1

Pan-European net settlement system

  • Operated by EBA Clearings.
  • Processes low-value (no minimum value threshold) and non-urgent Euro-denominated commercial payments.
  • STEP1 open to all banks in the EU and has access to EURO1 platform.

 

STEP2

Pan-European Automated Clearing House (ACH)

  • Operated by the Euro Banking Authority (EBA) Clearings.
  • Processes low-value, non-urgent and bulk Euro-denominated retail payments.
  • Provides straight-through processing for interbank transactions.
  • Settlement done same or next day, depending on time of submission.
  • A pan-European real-time infrastructure for EUR-denominated transactions is under development by EBA Clearing and Italy’s SIA Group (one of the operators of STEP2).
  • Cross-border transactions can be processed through SWIFT and overseas correspondent banks.
  • Luxembourg has eight participant banks.

SEPA

(Single Euro Payments Area)

EU-integrated payment infrastructure 

  • Pan-EU standardised electronic payment system, set up for settlement of EUR-denominated credit transfers and direct debits.
  • Not applicable to urgent, high-priority transactions. There is no value threshold.
  • Jurisdictional scope of SEPA is the 28 EU member-states plus Iceland, Norway, Liechtenstein, Switzerland, Monaco and San Marino.
  • In Luxembourg SEPA is implemented by the Luxembourg Bankers Association (Association des Banques et Banquiers, Luxembourg (ABBL)).

 

 

 

Payment Instruments

 

Credit Transfers

  • All credit transfers are automated.
  • High-value and urgent credit transfers are settled through TARGET2 in real time.
  • Low-value and non-urgent SEPA credit transfers are cleared through STEP2 same day.
  • Credit transfers used for payroll, supplier and third-party transactions.
  • The SEPA Credit Transfers (SCT) scheme is used for retail transactions and is available for urgent and high-priority payments (no maximum threshold) within the SEPA. 

 

Direct Debits (auto-debits)

  • Direct debits used for low-value, regular payments such as utility bills.
  • The SEPA Direct Debit (SDD) scheme is used for urgent and high-priority retail payments (no maximum threshold) within the SEPA. It is mandatory for all banks in the Eurozone to offer SDD facilities and banks outside of the Eurozone are required to accept SDD transactions.
  • SEPA SDD transactions cleared same day through STEP2.

 

Card Payments

  • Payment cards are becoming increasingly popular. Payment cards transactions accounted for 59% of the volume of cashless payments (excluding electronic money payments). 
  • The main payment card brands are Visa and MasterCard, although American Express and Diners Club credit cards also have a presence. All payment cards are SEPA- and Europay, MasterCard and Visa (EMV)-compliant.
  • Card payments are mostly processed through SIX Payment Services (card-processing company with major presence in Switzerland, Austria and Luxembourg), except American Express and Diners Club, which use their international card schemes.

 

Electronic Payments

  • Electronic payments (e-payments) are a common form of cashless payment in Luxembourg, accounting for EUR 75,093 billion worth of payments in 2015.
  • All the major banks as well as online e-payment providers (such as Paypal, Cashcloud and Saferpay) offer online and mobile payment services.
  • There are also reloadable prepaid cards available such as Easy card offered by Visa and Neteller.
  • MultiLine is the electronic banking application used to settle payments before they are processed through SIX Payment Services. It supports EBICS (Electronic Banking Internet Communication Standard) which is a SEPA-compliant transfer protocol. 

 

Other Payment Schemes

  • Cheques are only issued as bank drafts and cheque books are no longer issued by the banks. Cheques are cleared between banks.
  • Mobile payments: The use of mobile payments is on the rise, with 52% of mobile owners using mobile banking, and the ING International Survey on Mobile Banking 2016 noting that Luxembourg has the third-highest use of mobile banking in Europe.

 

Demographics

Recent developments

 

Luxembourg in Japanese FinTech tie up

The Luxembourg House of Financial Technology Foundation has signed a Memorandum of Understanding with the FinTech Association of Japan. The move will see Luxembourg become a FinTech hub helping Japanese companies potentially access the European Union, while also enabling European FinTech startups to explore possibilities in Japan. The move follows the Luxembourg-Japan Business Forum held in Tokyo.

Read more about this development here.

 

FinTech Collaboration Venture

The Luxembourg Bankers’ Association and the Digital Banking and FinTech Innovation Cluster have launched a FinTech Services Pack to encourage deeper cooperation between banks and technology firms. The services pack enables FinTech firms and specialised software providers to connect with members of the Luxembourg Bankers’ Association, including banks, payment companies, law firms, consultants and other financial services professionals, to exchange knowledge and experience and work together to shape financial services in Luxembourg.

Read more about this development here.

 

Increase in internet banking

Three-quarters of people in Luxembourg now use internet banking, up from 65% in 2015. The figure is considerably higher than the European Union average of just 51% of adults. But Luxembourg lags some European Union countries, with take up of online banking highest in Denmark, where 90% of adults carry out transactions over the internet, followed by the Netherlands at 89% and Finland at 87%. Overall, Luxembourg had the sixth highest level of internet banking users in the European Union.

Read more about this development here.

 

 

This Market Profile is brought to you by DBS. Get in touch with us for further insights on doing treasury in Luxembourg and take advantage of our innovative solutions to empower your business. Click here to find out more.

 

 

Sources: IMF World Economic Outlook database, October 2016; CIA World Factbook; Trading Economics; PwC

Please note that the information contained in this document, assembled based on information available and accurate as at July 2017, is of a general nature only and is subject to change whether for economic, political, social or other reasons.

 

 

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Last updated on 22 Feb 2018