Luxembourg: VAT-free zone regime offers favourable conditions for transactions in high-value goods

International Tax Review is part of Legal Benchmarking Limited, 1-2 Paris Garden, London, SE1 8ND

Copyright © Legal Benchmarking Limited and its affiliated companies 2026

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement

Luxembourg: VAT-free zone regime offers favourable conditions for transactions in high-value goods

intl-updates

Companies and individuals owning (or seeking to acquire) high-value goods should be aware that Luxembourg offers VAT and customs regimes that provide favourable conditions for certain transactions involving such goods.

Luxembourg law provides for a VAT suspension regime for goods introduced into a free zone or free warehouse. When combined with a similar regime applicable for customs duties, this may be particularly attractive for high-value goods. In this environment, the Luxembourg Freeport opened in September 2014. Located at Findel airport, the freeport offers a high-security and high-technology logistics hub within which high-value goods (e.g. art, wines, classic cars, precious metals, jewels, cigars, etc.) may be handled, stored, conserved, traded, restored and exhibited.

Under the tax regime (which is unlimited in time), a VAT and customs duty suspension will apply upon the entry of goods into the regime, as well as to any related transactions carried out during the period of storage (e.g. purchase and sale transactions). Services related to the goods (e.g. storage, restoration, etc.) also are covered by the exemption. It is noteworthy that goods may be temporarily removed for up to an entire year (e.g. for an exhibition in a museum or an art fair) without losing the benefit of the tax regime.

The goods will be subject to VAT and customs duties when they are withdrawn from the free zone, depending on the transaction carried out by the person withdrawing the goods from the regime. The suspension of VAT on all purchase and sales transactions carried out before the goods were withdrawn from the tax regime will end, and VAT will become due.

For example, import VAT will be due in the case of a permanent import into the EU of goods originating from a non-EU country, for both taxable and non-taxable persons. It is worth considering that the EU member state of importation will not necessarily be the one where the importer resides or is established, and this may have an impact on the applicable VAT rate. If the non-EU goods are exported out of the EU, the export would be exempt from VAT. Similar rules will apply to EU goods: when the goods are withdrawn from the VAT regime, they will be subject to VAT depending on their final destination. They may be exported outside the EU exempt from VAT, or sold and transported to a taxable person established in another EU member state who will have to pay the VAT in line with the rules of the member state where the goods are transported.

The VAT-free zone regime allows transactions to be carried out in goods without the immediate payment of VAT. This should help improve the buyer's cash flow, by allowing it to pay the VAT only when the goods leave the regime, and only if the transaction carried out at that time effectively triggers payment of VAT. The regime should be of particular interest for private art collectors, European art galleries and private museums, corporate structures and other vehicles owning high-value goods. An individual analysis of the relevant transactions is recommended, however, due to the diversity of situations and the complexity of the rules.

glohr.jpg
lambion.jpg

Raphaël Glohr

Michel Lambion

Raphaël Glohr (rglohr@deloitte.lu), Michel Lambion (milambion@deloitte.lu) and Cyrielle Gauvin (cyrgauvin@deloitte.lu)

Deloitte Luxembourg

Website: www.deloitte.lu

more across site & shared bottom lb ros

More from across our site

Pillar two has been clients’ ‘biggest headache’ but also a driver of growth for MHA, which believes it has the edge over its big four rivals
Public country-by-country reporting is exposing multinational tax data to investors, journalists and competitors, creating fresh risks for businesses
Pillar two compliance is creating unprecedented data demands for multinational tax departments, making closer collaboration with FP&A teams essential for accurate reporting and audit readiness
Among the arrivals is Andrew Howell, who leaves scandal-hit PwC Australia after representing PepsiCo in a high-profile TP dispute
ITR's podcast examines whether the big four have overarching cultural issues and assesses the competitive threat of technology-backed transfer pricing firms
The UK advisory firm has seen its global revenues expand by £27.2m following its listing and acquisition of Baker Tilly South-East Europe
Tax-trained John Sams, previously the firm’s CFO and COO, was appointed after a rigorous process, KPMG said
From Mauritius substance rules to Kenyan SEP tax and South African anti-avoidance measures, businesses must navigate growing scrutiny of cross-border IP structures in Africa
ITR spoke to multinationals, advisers and software providers about a June 30 deadline defined by faulty portals, high compliance costs and hard lessons
After years of onerous pillar two prep, businesses will be galled in seeing tax revenues outweighed by compliance costs
Gift this article