Corporate entities (Société Anonyme, Société a Responsabilité Limitée and Sociétés en Commandité par Actions) incorporated under Luxembourg law or having their principal establishment in Luxembourg are considered tax resident and subject to corporate income tax (Impôt sur le Revenu des Collectivités).
Corporate entities are subject to either a minimum income tax of EUR 3,210 or to a progressive minimum income tax from EUR 535 to EUR 21,400 that depends on the total assets on their balance sheet.
The Luxembourg Budget Law refined the scope of application of the minimum corporate income tax. As of January 1, 2015 the criteria for the application of the minimum income tax of EUR 3,210 have been revised. A corporate entity must own qualifying holding and financial assets that exceed 90% of its balance sheet and have a total balance sheet exceeding EUR 350,000 to be liable to the EUR 3,210 minimum income tax. Entities that meet the 90% test and have a total balance sheet below EUR 350,000 would be liable to a minimum income tax of EUR 535 (previously EUR 3,210).