Next-Gen Wealth: Luxembourg’s Strategic Role in Multi-Jurisdictional Structuring and Succession
Luxembourg has firmly established itself as a pivotal node in European wealth structuring, managing over one trillion euros in assets and standing among the leading hubs for regulated funds (UCITS, RAIF, SIF, SICAV) and SOPARFI holding companies. This leadership position is no coincidence; it is the direct result of an environment where entrepreneurial families and pan-European family offices must blend technical sophistication, regulatory compliance, and long-term vision. In this context, Luxembourg is much more than an efficient jurisdiction: it is the stage on which the new rules for protecting and transmitting wealth are being defined.
The relationship between Luxembourg and Spain has become increasingly strategic, built on solid foundations. The network of double taxation agreements (DTAs) and the compatibility of both countries’ succession frameworks allow for fluid mobility of family capital. Luxembourg, therefore, becomes the natural partner for those seeking to combine legal certainty, flexibility, and global access. Through advanced vehicles—private foundations (Loi du 27 juillet 1922), purpose foundations, and roles such as the Protector—robust architectures are built for asset protection and intergenerational planning, fully aligned with CRS, FATCA, and UBO registers (RCBE).
“The relationship between Luxembourg and Spain has become increasingly strategic, built on solid foundations. The network of double taxation agreements (DTAs) and the compatibility of both countries’ succession frameworks allow for fluid mobility of family capital.”
In parallel, the Dutch holding company plays a technically strategic role. Intelligently integrated into Luxembourg–Spain structures, it optimizes participation exemption (Art. 13 CITA 1969), eliminates double taxation of dividends through the Parent-Subsidiary Directive, and ensures efficient cross-border flows—all under strict substance and reporting requirements (CBCR, DAC6, ATAD3). This way, the pan-European architecture is not only tax-efficient but also legitimate and auditable in each relevant jurisdiction.
Yet, wealth engineering extends well beyond tax. Luxembourg has adapted its vehicles to meet the challenges of BEPS 2.0, ATAD, and the ever-increasing focus on real substance (“substance over form”). The private foundation, combined with SOPARFI holding companies and alternative funds (RAIF, SIF), provides a platform for ring-fencing, differentiated governance, and access to alternative investments (PE, VC, RE). For those requiring additional flexibility, the Luxembourg legal framework facilitates the integration of trusts and purpose trusts under international private law, never losing sight of traceability and regulatory oversight.
The key lies in the professionalization of succession and family governance. It is no longer enough to secure generational transition from a testamentary perspective; now, it is essential to articulate family protocols, internal statutes, and conflict resolution mechanisms that respond to both technical criteria and ESG values, responsible investment, and legacy preservation. In fact, Luxembourg allows these elements to be incorporated into the founding documents themselves, making a decisive difference in multigenerational wealth management.
This sophisticated ecosystem could not function without robust financial education, intergenerational mentoring, and the support of private banks and multi-family offices. All of this ensures an orderly, auditable handover fully compliant with European legislation, including the new requirements of the global minimum tax (Pillar 2, GloBE).
“The key lies in the professionalization of succession and family governance. It is no longer enough to secure generational transition from a testamentary perspective; now, it is essential to articulate family protocols, internal statutes, and conflict resolution mechanisms that respond to both technical criteria and ESG values, responsible investment, and legacy preservation.”
Looking ahead to 2026, it is clear that resilience and excellence in wealth structuring depend on the ability to anticipate, document, and legitimize every strategic decision under any audit or regulatory scrutiny. In this respect, Luxembourg not only maintains its leadership but expands it, becoming the reference point for groups and families who understand that sustainable legacy is no longer about fiscal arbitrage but about transparent governance, traceability, and continuous adaptation.
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