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Luxembourg vs Ireland: which jurisdiction wins?

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

 LuxembourgIreland
Tax headline24.94% effective; SOPARFI structuring lowers materially12.5% trading, 15% Pillar 2 for large groups
Formation days145
First-year cost$12,000$5,500
Treaties85+75+
SubstanceSubstance mandatory post-ATADSubstance critical (CFC, BEPS)
BankingBIL, BGL BNP Paribas, prime brokersBOI, AIB, plus US bank branches

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