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Luxembourg vs Malta: which jurisdiction wins?

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

 LuxembourgMalta
Tax headline24.94% effective; SOPARFI structuring lowers materially35% headline, ~5% effective via refund system
Formation days147
First-year cost$12,000$4,500
Treaties85+70+
SubstanceSubstance mandatory post-ATADEU substance requirements + DAC6
BankingBIL, BGL BNP Paribas, prime brokersBank of Valletta, APS, plus EU EMIs

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