1. Is stamp duty, transfer tax or a similar tax payable on the direct sale, purchase or leasing of real estate? If so, what are the rates and who is required to pay the duty or tax?

Sale of real estate/properties under construction

The sale of a Luxembourg real estate/property located in Luxembourg entails payment of the following duties:

1. a 6% registration duty;
2. a municipal surcharge of 50% of the above registration duties for real estate located in Luxembourg city and affected to commercial use (i.e., 3%); and
3. a 1% transcription tax.

The above gives rise to an aggregate transfer tax of 10% in Luxembourg City for commercial properties, and of 7% elsewhere in the country and in Luxembourg City for residential properties.  This charge is computed on the sale price as determined by the parties. It must correspond at least to the estimated fair market value of the real estate and it is payable by the buyer (unless otherwise provided by contract).  

The registration duties are in principle due by the buyer. 

However, certain registration duties abatements are available:

• The law of December 20, 2020 on state revenue and expenditure budget for 2025 introduced a 50% tax abatement (applicable on the tax basis) for the acquisition of a property to be used as personal housing or as a housing for a tenant. This tax measure is limited in time and applies retroactively to notarized deeds of acquisition passed between October 1, 2024 and June 30, 2025.
• A tax credit of €30,000 per person (€60,000 for couples) is available for the acquisition of a property to be used as personal housing (so-called “Bëllegen Akt”). The abatement was increased to €40,000 per person (€80,000 for couples) during the year 2024 and it is expected that this increased €40,000 credit will be extended for notarized deeds of acquisition passed until June 30, 2025 (even if not yet enacted).
• A tax credit of €20,000 per person (€40,000 for couples) was introduced for investments in newly built properties to be used as rental housing with a rental period of more than two years. This tax credit is available for the year 2024 only but it is expected that this credit will be extended for acquisitions realized by way of notarial deed passed until June 30, 2025 (even if not yet enacted).

Letting/lease of real estate

As of January 1, 2017, there is no longer a requirement to register leases, subleases and subrogation of leases within three months of their signature.

However, leases with a term of more than nine years are still subject to a transcription formality, which requires the lease to be registered. They are hence subject to registration duties at a rate of 0.6% on the cumulative amount of rent on the total duration of the lease, except for leases subject to value added tax (VAT) for which registration duties are fixed at €12 (see below). 

For the purposes of payment and the assessment of the duties, leases concluded for three, six or nine years will be deemed to be nine-year leases.

Leases not subject to the registration/transcription formality may still be registered on a voluntary basis, in which case the same 0.6% registration duties per annum would be due.

Leases concluded for an unlimited duration are assimilated to a sale and subject to registration duties at an aggregate 7% rate (split between a 6% registration duty and a 1% transcription duty). The municipal surcharge of 3% described at question 1 may also apply. The taxable basis is based on the equivalent of 20 years’ rent and charges.

If the lease is subject to VAT (see question 3 below), by an option granted beforehand, only a fixed registration duty of €12 is due (i.e., the above ad valorem registration duties do not apply). In application of the non bis in idem principle, if VAT applies, there is no registration duty, regardless of whether or not the lease is for more than nine years. 

Property leasing contracts (crédit-bail immobilier) are only subject to the €12 fixed registration duty (and not the ad valorem registration duties) provided certain conditions are met. Where the lessee acquires the property at the end of the contract, registration duty at the proportional rate of 7%/10% should be payable on all payments representing the sale price made both during the lease and at the time of transfer.

In practice, the registration duty is due by the tenant in the absence of any other agreement providing for joint and several liability.

2. Is stamp duty, transfer tax or similar tax payable on the indirect sale or purchase of real estate, e.g., by means of the sale of an SPV which holds real estate in the jurisdiction? If so, what are the rates and who is required to pay the duty or tax?

There are no transfer taxes (stamp duty or similar duties/taxes) payable on the sale of shares in a Luxembourg tax opaque company (such as, notably, SA, Sàrl., SAS, SCA).

Registration duties apply in the case of a sale of the shares/units of a Luxembourg tax transparent entity (such as, notably, a SCI, SCS, or SCSp) holding Luxembourg real estate (which are assimilated to a direct sale of the real estate). 

The same registration duties as for a direct sale of an asset apply, except the 1% subscription tax is not applicable.

3. Is value added tax, goods and services tax or a similar tax payable on the sale or purchase of real estate, and the letting of real estate? If so, what are the rates and who is required to pay the tax?

Real estate transactions are generally VAT exempt. 

However, under certain conditions, the owner of real estate property has the option to waive the VAT exemption and to apply VAT on lease or sale of real estate. This may entitle the lessor/seller to deduct, to a certain extent, the value of any input VAT incurred.

In addition, the sale of buildings under construction or to be constructed at the time of signature of the agreement in principle subject to VAT at standard 17% (or at the reduced 3% rate if the building is used as main residence by the buyer).

VAT exemptions and VAT application for non-exempted transactions

Transactions exempt from VAT include:

1. The supply (livraison) of a building (and of the land on which it stands) and the transfer or real estate property rights, other than the sale of buildings under construction or to be constructed at the time of signature of the sales agreement.
2. The leasing or letting of immovable property. However, the exemption does not cover:
   
   1. the provision of accommodation in hotels or similar establishments;
   2. the letting of premises and sites for the parking of vehicles;
   3. the letting of permanently installed equipment and machinery;
   4. the renting of safety deposit boxes; and
   5. additional services provided in addition to a furnished lease, such as common reception, concierge services etc. are considered supplies of services and are fully taxable at 17% VAT standard rate.

Among other factors, the proper VAT treatment of the sale of real property depends on whether:

1. the object of the sale is classified as a going concern: if so, the sale falls outside the scope of VAT;
2. the plot of land subject to the sale is developed or not: if a plot of land is developed, the VAT treatment of land follows the VAT treatment of buildings or constructions (or their parts) developed thereon;
3. the undeveloped land is designated for other purposes than development: if so, such supply is generally exempt from VAT.

VAT option for the sale/lease of real estate

An option for the sale/lease of real estate can be subject to VAT, provided the following conditions are met:

1. the sale/lease must take place between VAT taxable persons (the seller and the purchaser/the landlord and the tenant must be registered for VAT and carry out transactions subject to VAT);
2. the property must be used by the purchaser/tenant, wholly or, in the case of mixed use, at least predominantly (more than 50%), in connection with an economic activity that gives entitlement to input VAT recovery;
3. a declaration of option for approval must be submitted to the Administration de l’Enregistrement, des Domaines et de la TVA.

Provided the above conditions are met, the sale/lease will be subject to VAT at the standard 17% rate on the net price.  

Hence, no VAT option is possible for the lease of residential units for housing purposes.  

4. Are there any annual taxes that may be payable on the ownership of real estate, e.g., annual land tax, municipal taxes, surtaxes, etc.?

Property tax (impôt foncier)

Property tax is charged annually by municipalities at varying rates, depending on the location and nature of the property.

The property tax due corresponds to the tax base (base d’assiette) multiplied by the communal rate (taux communal). The tax base is itself obtained by multiplying the unitary value of the property (valeur unitaire) by the base rate (taux d’assiette).

The unitary value of the properties reflects the theoretical value of the property as of January 1, 1941. Therefore, the amount of property tax due is currently minimal.

In October 2022, the Luxembourg Government submitted the bill of law 8082 to the Luxembourg Parliament to introduce a reform of the property tax regime. The bill of law contains many modifications including that the unitary value should reflect the building potential of the property and that communal rates would range between 9% to 11%. The bill of law has not yet been adopted.

Net wealth tax for companies (impôt sur la fortune)

There is no net wealth tax for individuals, but there is a wealth tax for corporations.

Real estate properties located in Luxembourg held by a Luxembourg company or by a non-resident through a Luxembourg permanent establishment (PE) are subject to annual net wealth tax applying on the unitary value of the properties as determined on January 1 of each year.

Net wealth tax is levied at rate of 0.5% up to net wealth of €500 million and at 0.05% for net wealth of more than €500 million.  

Real estate properties abroad are excluded from the net wealth tax basis of Luxembourg companies/Luxembourg PE to the extent exclusively taxable in the source state under an applicable double tax treaty (DTT).

Specific tax on vacant housing

A few municipalities in Luxembourg currently have regulations introducing a specific tax on vacant buildings and unallocated building land. These are Beckerich, Diekirch, Esch-sur-Alzette, Esch-sur-Sûre and Redange-sur-Attert.

5. What is the tax rate imposed on rental income?

Resident individual taxpayers

For individuals acting in the course of the management of their private wealth, net rental income (income after all deductions and amortization) is subject to progressive personal income tax from ranging 0% to a maximum effective marginal tax rate of 42% for income over €220,788 (€441,576 for spouses assessed jointly), increased by a 7% solidarity surcharge applied on the tax amount for income below €150,000 and 9% above (the threshold is set at €300,000 for couples assessed jointly). There is an additional long-term care contribution (assurance dépendance) of 1.4% on income.

For individuals, acting in the course of a professional activity, the rental income is a business income subject to the above progressive personal income tax rates (including the solidarity surcharge). In addition, those individuals will, in principle, also be subject to municipal business tax (MBT) the rate of which varies between municipalities (6.75% per year in Luxembourg City). 

Resident corporate taxpayers

Luxembourg resident fully taxable companies (such as notably SA, Sàrl, SAS, SCA). or non-residents companies acting through a Luxembourg PE are subject to Luxembourg corporate income tax (CIT) at a rate of 17% and MBT until 2024 (reduced to 16% as of 2025). In Luxembourg City, the aggregate standard rate is of 24.94% (including the solidarity surcharge) until 2024 (reduced to 23.87% as of 2025). These taxes are due on net rental income (i.e., income minus deductible expenses) derived from real estate properties located in Luxembourg.  

Non-resident corporate taxpayers

For non-resident corporate taxpayers, in the absence of a Luxembourg PE, rental income is only subject to CIT at 17% (income exceeding €200,000) until 2024 (reduced to 16% as of 2025). No MBT applies unless the property is held through a PE in Luxembourg). 

6. Is interest on borrowings used to acquire real estate deductible for tax purposes against rental income? If so, (i) are there any restrictions, such as thin capitalization, transfer pricing or interest limitation rules, and (ii) Is there any withholding tax on the interest?

Corporate taxpayers

For corporate owners of real estate, the funding of the acquisition of real estate will need to comply with general transfer pricing rules. There are no formal thin capitalization rules in Luxembourg.

Interest Deduction Limitation Rules 

Luxembourg has implemented the interest deduction limitation rules (IDLR) contained in EU directive 2016/1164 dated July 12, 2016 (ATAD 1) in its domestic legislation. The IDLR is applicable since January 1, 2019. 

According to the IDLR, the deduction of a taxpayer’s exceeding borrowing costs is limited to the higher of €3 million or 30% of the taxpayer’s EBITDA (i.e., taxable earnings before interest, tax, depreciation and amortization). A taxpayer’s borrowing costs are in excess if “interest expenses on all forms of debt and others costs economically equivalent to interest and expenses incurred in connection with the raising of finance” exceed the “interest revenues and other economically equivalent taxable revenues.”

The IDLR apply to all entities subject to Luxembourg CIT and to all interest-bearing loans and securities.

Transfer Pricing

The Luxembourg transfer pricing rules are covered by the provisions of the articles 56 and 56bis of the Luxembourg income tax law (LITL). 

Where the acquisition by a Luxembourg company of a Luxembourg property is financed by way of a loan granted by a related party, the interest rate applied on such loan must comply with the arm’s length principle. If this is not the case, excess interest will not be deductible.

Anti-hybrid mismatch rules 

Luxembourg has transposed the anti-hybrid rules stemming from EU Directive dated May 29, 2017 (ATAD 2) into domestic legislation. 

ATAD 2 addresses several categories of hybrid mismatches that exploit differences between tax systems to achieve double non-taxation (or long-term tax deferrals): double deduction, deduction without inclusion, non-taxation without inclusion. 

To neutralize these mismatches, Luxembourg is required to: (i) deny the deduction of payments, expenses or losses; (ii) include payments as taxable income, or; (iii) deny relief from double taxation.

ATAD 2 only applies to Luxembourg companies.

Interest payments are, in principle, not subject to withholding tax (WHT) in Luxembourg, except in limited cases such as:

1. where the interest rate does not comply with the arm’s length principle (e.g., because the interest rate is excessive): excessive interest on borrowing may be requalified as hidden dividend distribution in principle subject to a 15% WHT;
2. interest on certain income sharing type instruments;
3. interest paid by Luxembourg paying agents to Luxembourg individual resident (so-called “Relibi Law”) for which a 20% WHT is applicable.

Individual taxpayers

Interest paid by individuals in relation to mortgage loans used to finance the acquisition of their main residence are deductible in amounts varying between €2,000 and €4,000 per person in the household, depending on the number of years the main residence has been occupied.

7. Are deductions for capital expenditure available against rental income for tax purposes, for example capital allowance or deductions for depreciation? If so, are deductions available for expenditure on both land and buildings, or on buildings only?

Deductions for depreciation/amortization are available against income for tax purposes. Only constructions may be amortized but not the land.

Where the property is held in the private wealth of an individual

For an individual acting in the course of her/his private wealth, amortization is a deductible expense (frais d’obtention) to be deducted from the rental income in order to obtain the net rental income.

The amortization base (base de l’amortissement) depends on whether the property was acquired (i) for consideration or for free and (ii) before January 1, 1941 or thereafter.

A distinction must be made between properties used for rental housing (logement locatif) and others.

1. Properties held for rental housing: the standard amortization rate is 2%. However, a 4% rate  is available for (up to two) properties which are within five years of completion (achèvement) on 1 January of the tax year.
   
   On top, a special property allowance (abattement immobilier special) is also available for properties acquired after December 31, 2020 used for rental housing and benefiting from the above 4% rate. The amount of the allowance is 1% of the sum of the values used to calculate the 4% rate mentioned above, up to a maximum of €10,000. Such allowance is deductible from the taxpayer’s taxable amount (revenu imposable) as opposed to a deductible expense.
   
   In addition, a temporary special construction allowance (abattement construction spécial) was introduced for buildings or parts of buildings under construction for which the taxpayer has signed between January 1, 2024 and December, 31 2024 a deed of sale in a future state of completion (vente en l’état future d’achèvement) and the completion of which was less than six years prior to 1 January of the tax year. The said building must be used for rental housing. The amount of the allowance is 4% of the sum of the values used to calculate the 2% rate mentioned above, up to a maximum of €250,000. It is expected that this measure will be extended for acquisitions realized until June 30, 2025 (even if not yet enacted).
   
   Note that (i) the 6% rate for properties acquired before January 1, 2021, the completion (or renovation) of which is less than six years old and (ii) the 4% rate for properties acquired after December 31, 2020 and before January 1, 2023, the completion (or renovation) of which is less than five years old, are still in force.
   
   An amortization rate of 6% is available for capital expenditure (dépenses d’investissement) on sustainable energy renovation the completion of which is, on January 1 of the tax year, less than nine years old.
2. Properties not held for rental housing: the amortization rates vary depending on the age of the property. A distinction is made between buildings that are less than 30 years old, buildings that are 30 years old or more but not more than 60 years old, and buildings that are more than 60 years old. Depending on the age of the building, the rate of depreciation is 1.5% to 3%. Increased rates (2% to 4%) are available in the case of greater wear and tear to the extent this is duly justified.

Where the property is held as a business asset by an individual or a company

For an individual acting in the course of a professional activity, amortization is a deductible business expense (dépenses d’exploitation) to be deducted from the rental income in order to obtain the net rental income.

The amortization basis consists of the acquisition price minus the residual value:

1. Properties held for rental housing: a straight-line amortization rate is in principle applied. However, an accelerated amortization rate of 4% is available for properties the completion (achèvement) of which is, on January 1 of the tax year, less than five years old. Note that the 6% rate for properties acquired before January 1, 2021, the completion of which is less than six years old (the same is also available for renovation works) is still in force.
   
   An amortization rate of 6% is available capital expenditure (dépenses d’investissement) on sustainable energy renovation the completion of which is, on 1 January of the tax year, less than nine years old.
   
   The special property allowance (abattement immobilier special) discussed above is also available here (but not the temporary special construction allowance (abattement construction spécial)).
2. Properties not held for rental housing: straight-line amortization rate is in principle applied.

For companies holding property, the same treatment as the one described above for individuals acting in the framework of a professional activity applies, except that the special property allowance (abattement immobilier special) is not available for companies. 

For non-residents

For non-residents, amortizations depend on whether the activity is commercial or not, with certain specificities.

8. Are there any other material restrictions on the costs and expenses which may be reduced in calculating a person’s taxable rental income, e.g., transfer pricing or anti-hybrid rules? 

Generally, costs and expenses (maintenance and repair costs, expenses for acquisition, depreciation/amortization, interest payments) are deductible subject to compliance with the transfer pricing rules, interest deduction limitation rules and anti-hybrid mismatch rules. 

9. Are there any restrictions on the use, and/or carry forward, of losses?

For all Luxembourg resident taxpayers, as of January 1, 2017, only tax losses incurred during the 17 tax periods preceding the tax period for which the deduction is claimed will be deductible.  Tax losses incurred between January 1, 1991, and December 31, 2016, can still be carried forward without any time limitation. The old tax losses are to be deducted first.

For individual Luxembourg resident taxpayers, the carryforward of income tax losses is only possible for losses deriving from professional activities.

10. Are capital gains arising on the direct sale of real estate taxable? If so, what are the rates and are there any exemptions?

Capital gains arising on the sale of real estate are taxable.

For resident individual taxpayers

Capital gains on real estate realized by individuals acting in the course of the management of their private wealth, are taxable either as speculative gains if realized within two years of the acquisition until 2024 (extended to five years since 2025) or as an extraordinary gain on sale. 

• Speculative gains (i.e., capital gains realized on a sale less than 2 years after acquisition until 2024 (extended to five years since 2025)) are fully taxable at the progressive tax rate increased by the solidarity surcharge.
• Gains realized upon the sale of real estate (after two years) benefit from a €50,000 (€100,000 with spouses) tax allowance (abattement fiscal) and are taxed at half the progressive income tax rate. In addition, a deduction up to €75,000 for inherited property (through the direct line of descendance) may apply.

In both cases, capital gains realized upon the sale of the main residence are fully tax exempted.  

Capital gains realized by individuals in the course of their profession are taxable at progressive income tax rates and are also subject to MBT at 6.75% (in Luxembourg City). 

As a temporary measure to boost the housing market in Luxembourg, in the year 2024 only, the overall capital gains tax rate on the sale of real estate was reduced to 25% of the progressive income tax rate. This measure is not applicable to speculative gains. It is expected that this measure will be extended for acquisitions realized until June 30, 2025 (even if not yet enacted).

A roll-over mechanism was temporarily introduced solely for fiscal year 2024 according to which individual taxpayers could transfer the capital gain realized on the sale of a property to replacement properties used for social rental management or with the highest energy performance classification (A+).

For resident corporate taxpayers

Gains realized upon the sale of real estate are fully taxable at 24.94% CIT and MBT, including the 7% solidarity surcharge, until 2024 (23.87% as of 2025).

However, provided certain conditions are met, the capital gain can be neutralized from a tax perspective by transferring the capital gain to fixed assets acquired or constituted in reinvestment.

For non-residents

Where the capital gain is realized by a non-resident individual (not acting through a Luxembourg PE):

• speculative gains are fully taxable at the progressive tax rate increased by the solidarity surcharge;
• gains realized upon the sale of real estate (after two years until 2024 (extended to five years as of 2025)) are taxed at half the progressive income tax rate (subject to a minimum 15% tax rate).

Capital gains realized upon the sale of a real estate property located in Luxembourg by a foreign entity are taxable in Luxembourg and subject to CIT at 17% rate until 2024 (16% as of 2025) plus the solidarity surcharge. If the Luxembourg property is attributable to a Luxembourg PE, MBT will also be due – representing an aggregate CIT and MBT rate of 24.94% (including the solidarity surcharge) if located in Luxembourg City until 2024 (23.87% as of 2025).

11. Are capital gains arising on the indirect sale of real estate taxable, e.g., by means of the sale of an SPV which holds real estate in jurisdiction? If so, what are the rates and are there any exemptions?

Sale of a Luxembourg tax transparent entity

The sale of the shares/units in a tax transparent entity (such as, notably, a SCI, SCS or SCSp) holding Luxembourg real estate held by a:

1. Luxembourg resident individual (regardless of whether that person acts in the course of their private wealth or in the course of a professional activity);
2. Luxembourg company; or
3. non-resident,

is in principle assimilated to the direct sale of the property in proportion to the participation held in the transparent entity – please refer to the tax consequences described above.

Sale of a Luxembourg tax opaque entity

1. For an individual acting in the framework of its private wealth, a capital gain realized upon the sale of a Luxembourg capital company holding Luxembourg real estate will only be taxable if:
   1. it constitutes a speculative gain (i.e., the sale occurs six months or less after acquisition): in which case the capital gain will be fully taxable at the progressive tax rate increased by the solidarity surcharge;
   2. it is sold more than six months after the acquisition and the person holds a substantial participation in the company (i.e., a participation of more than 10% together with their partner and underage children in the five years preceding the sale): in which case the capital gain will be taxable at half the progressive income tax rate increased by the solidarity surcharge.
2. For an individual acting in the framework of a professional activity, capital gains are taxable at progressive rates and subject to the solidarity surcharge).
   
   However, provided certain conditions are met, the capital gain may be neutralized/rolled-over by transferring the capital gain to fixed assets acquired or constituted as reinvestment.
3. A Luxembourg taxable company realizing a capital gain upon the sale of the shares in another Luxembourg taxable company should be fully taxable on such capital gain. A full exemption on such gain may be available under the participation exemption regime (minimum of 10% shareholding or shares of an acquisition value of €6 million in a fully taxable limited company held for at least 12 months).
4. Concerning non-residents, many of the double tax treaties concluded by Luxembourg do not contain a real-estate rich clause. Hence, the sale of the shares in a Luxembourg company by a non-resident is generally only taxable in the jurisdictions of the seller.
   
   For non-residents in a country which has not concluded a double-tax treaty with Luxembourg, Luxembourg capital gain taxation will only be due if cumulatively (i) the non-resident sells the participation within six months of the acquisition and (ii) he/she/it holds a substantial participation (see above) in the Luxembourg company.

12. Is there a withholding tax on rental income?

No, Luxembourg does not impose withholding tax on rental income.

13. Is there a withholding tax on capital gains derived from real estate? If so, does the withholding tax apply to both direct and indirect sales, or to direct sales only?

No, Luxembourg does not impose withholding tax on capital gains deriving from real estate, except for the real estate levy (see question 14 below). 

14. Does the jurisdiction have a REIT regime? If so, please outline the tax treatment of the REIT and the main conditions that must be satisfied to enter and remain within the regime. 

Luxembourg currently does not offer a real estate investment trust (REIT) regime. 

Despite the absence of such a regime, Luxembourg offers a wide range of other legal products to initiators, promoters and sponsors in the real estate investment business, which, although not specifically tailored to real estate investments, are suitable and widely used to acquire, develop and hold Luxembourg or foreign real property (such as specialized investment funds or reserved alternative investment funds). 

That being said, the Law of December 19, 2020 on state revenue and expenditure budget for 2021 introduced a 20% real estate levy (REL) (prélèvement immobilier) on income derived from real estate (rental income, capital gains related to the sale of the assets, transfer of units or shares) situated in Luxembourg by certain Luxembourg investment funds (directly or through transparent entities).

Investment funds in scope include entities with a legal personality (but excluding the limited partnership – société en commandite simple) subject to the law of:

• December 17, 2010 relating to undertakings for collective investments (the so-called “Part II Funds”);
• February 13, 2007 relating to specialized investment funds (SIFs); and
• July 23, 2016 relating to reserved alternative investment funds (RAIFs).

The REL is to be declared and paid by the investment vehicle itself. The declaration must be made no later than May 31 following the calendar year in which the income is received or realized. The investment fund must then make payment to the Luxembourg tax authorities by the following June 10 at the latest. 

15. Apart from REITs, are there any tax-efficient real estate investment vehicles or structures which are commonly used to acquire, hold and exploit real estate in the jurisdiction?

Luxembourg’s legal framework offers different investment vehicles and various structures for the holding of real estate.  Both regulated as well as unregulated vehicles are available.  

16. Are there any structures commonly used to mitigate real estate tax liabilities on acquiring and/or disposing of real estate?

The majority of transactions are generally carried out through a share deal rather than an asset deal, as the target company that holds the real estate can carry forward its losses and the purchaser can avoid registration duties (i.e., 0% versus 10%). 

In addition, capital gains realized on shares of a Luxembourg property company may be exempt under the conditions of the participation exemption regime if, amongst others, the parent company holds or commits to hold a participation of at least 10% or of an acquisition price of at least €6 million for at least 12 months in the eligible subsidiary.

17. Are there any material differences in the way individuals and companies are taxed on acquiring, letting and/or disposing of real estate?

Capital gains realized on the disposal of real estate properties in Luxembourg will be taxed at 24.94% CIT/MBT until 2024 (23.87% as of 2025), versus a maximum 21% personal income tax rate for individuals under certain conditions.

Individuals, including individual enterprises, are not subject to net wealth tax.

This guide does not constitute tax advice and readers should note that the laws of each jurisdiction are regularly refined and/or revised, so the statements made in this report are not definitive. However, this guide does provide a summary overview of the state of the law as at 31 January 2025 and will hopefully serve as a useful tool for investors to ensure they understand the unique provisions and distinctions in the various jurisdictions.