From Luxembourg to Mallorca, via the Netherlands: How Multi-Jurisdictional Structures Create Strategic Value
Last week, I had the pleasure of attending Spain’s National Day reception, organized by the Embassy of Spain in Luxembourg at the iconic Cercle Cité . Beyond the formalities, the conversations confirmed a growing trend in European corporate structuring: the increasing convergence of Luxembourg and Dutch holding structures with Spanish operational presence, particularly in Mallorca and the Balearic region.
Luxembourg remains a jurisdiction of reference for investment vehicles, finance platforms, and capital optimization. However, in today’s regulatory climate shaped by BEPS, ATAD, DAC6 and enhanced economic substance requirements, Luxembourg alone is rarely sufficient. Many investors are complementing their structures with Dutch BV´s at the top, benefiting from full participation exemption, broad treaty access, and robust governance, while maintaining Luxembourg-based financing vehicles and adding Spanish entities for operational substance.
This tri-jurisdictional setup can yield significant fiscal efficiencies. For example, by structuring profit flows through the Netherlands and Luxembourg, and aligning with EU directives such as the Parent-Subsidiary Directive and Interest & Royalties Directive, total effective tax exposure on repatriated profits can be reduced by 25–35% compared to single-jurisdiction setups — all while maintaining full compliance with EU transparency standards.
A practical case: a European family office holds its strategic assets via a Dutch B.V., channels intra-group loans and mezzanine instruments through a Luxembourg Sàrl and operates a Spanish S.L. in Mallorca for local hiring, project execution and EU grant access in renewable energy. This structure offers both legal robustness and geographic alignment with the client’s investment footprint and succession planning.
The Netherlands offers predictability, administrative efficiency and an investor-friendly framework. Luxembourg brings sophistication in financial structuring, while Spain — particularly the Balearic Islands anchors the operation with real economic substance, regional incentives, and long-term lifestyle value for mobile entrepreneurs. This combination is increasingly popular among international families, holding companies, and mid-sized funds.
Working alongside trusted experts like PYR Asesores , and with institutions such as ICEX and the Official Spanish Chamber of Commerce in Belgium and Luxembourg , to implement compliant, efficient and long-term structures tailored to each client’s strategic priorities.
Montclare Advisory Board Willem Fenengastraat 16E, 1096 BN Amsterdam, the Netherlands contact@montclarecapital.com
