Luxembourg vs Netherlands: which jurisdiction wins?

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

	Luxembourg	Netherlands
Tax headline	24.94% effective; SOPARFI structuring lowers materially	25.8% corporate; participation exemption for holdings
Formation days	14	5
First-year cost	$12,000	$6,500
Treaties	85+	95+
Substance	Substance mandatory post-ATAD	Substance decree — mandatory directors, payroll, office
Banking	BIL, BGL BNP Paribas, prime brokers	ING, Rabobank, ABN AMRO

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