Luxembourg vs Delaware (USA): which jurisdiction wins?

Luxembourg vs Delaware (USA) — both credible, very different trade-offs. Below: side-by-side on the variables that actually move the decision.

	Luxembourg	Delaware (USA)
Tax headline	24.94% effective; SOPARFI structuring lowers materially	21% federal + 8.7% Delaware (no state tax on non-DE income)
Formation days	14	1
First-year cost	$12,000	$1,200
Treaties	85+	70+
Substance	Substance mandatory post-ATAD	US tax presence considerations
Banking	BIL, BGL BNP Paribas, prime brokers	Mercury, Brex, plus tier-1 US banks

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