Luxembourg topped the list for the most direct foreign investment per capita for the second year running in EY’s Luxembourg Attractiveness Survey. But the clear sense at a press conference held to release the second edition of the survey was that the country has to work hard to keep itself in this favourable position, increasing its attractiveness, defending its financial industry against EU anti-tax avoidance directives, as well as figuring out the issue of the talent gap.
Luxembourg had 5.83 projects per 100,000 people, up from 3.94 in 2021. Ireland, this country’s perennial competitor on the financial front, which came in second to Luxembourg in 2021 with 3.04, has dropped to third place, despite an increase to 3.68 projects per 100,000.
“What has become even more clear now, in this year of election, is that there’s a number of key ingredients underpinning all efforts to improve foreign direct investment in the country. These are talents and tax,” said Oliver Coekelbergs, EY’s country managing partner.
The forthcoming ATAD-3 “Unshell” directive, for example: “In the current wording of this directive, all these SPVs would be heavily targeted and it would have a very negative effect on Luxembourg,” said Bart van Droogenbroek, an EY Luxembourg partner and tax leader. “It’s very important that this text in its current wording evolves in a way that it would preserve the investment fund industry.”
Higher tax
“What we clearly see in the country is that there is a tendency to increase taxation on individuals,” said Van Droogenbroek. He cited OECD data showing that Luxembourg’s average tax rate is nearly 6 percentage points higher than the average OECD rate of 34.6%. “If you want to attract talent, it’s a handicap,” he said.
He identified the need for “certainty and clarity” as being “important to attract and keep the international business.” He deplored what he saw as more aggressive behaviour by the Luxembourg tax authority, saying that while this is normal in France or Germany, “if those groups are facing the same type of attitude in Luxembourg, well, they wonder why they should still stay in Luxembourg?”
He took the view that “Luxembourg has a role to play in order to clarify and to bring more certainty to the taxpayers, because it will keep business here and avoid that it will go away.”
A big decision
Discussing the OECD’s Pillar 2 and the global minimum corporate tax, however, Van Droogenbroek merrily recounted how “Luxembourg had a positive lever to pull.” He explained that under the qualifying domestic minimum top-up tax, Luxembourg had the choice to take advantage of its right to apply a 15% tax on top of existing tax rules if, under normal rules, companies get a tax rate under 15%.
If Luxembourg decides to introduce this supplemental tax, “we give a very important and positive message if Luxembourg could say that it would use these funds to fund tax breaks, to fund a reduction in tax rates, to fund the stimulation of business or let it flow back to the business,” he said, noting that “otherwise it would flow to other countries.”
Luxembourg came out of the survey as an attractive place for digital talents. But according to Lecoustay, this is a perception, but there are challenges in this area.
Foster workplace culture
He said that Luxembourg needs “to foster its workplace culture.” He pointed to the country being in a unique position with commuting or teleworking. “We need obviously to promote in a mature way or clarify the way telework or commuting is optimised, to value our workforce.”
He emphasised that instead of searching abroad, “we think that there should be a focus to develop the young Luxembourgish talents.” He said the country should improve its prioritisation of vocational-technical skills in the national curriculum, citing apprenticeship programmes in Germany or France.
He advocated the need for education to be offered “in a way which goes into the different elements of the economy.” But graduates “should stay in Luxembourg” and be able to connect “with training opportunities from Luxembourg companies like ours or the industries.” He advocated that by doing so, “we keep our uniqueness and train them to the future of the economy.”
“Without this, we will need to continue to be obviously attracting talent from abroad.” He said Luxembourg should further simplify administrative burdens and improve service levels.