If the individual is holding a participation in a company or some convertible debts issued by such a company, the appreciation in value from its acquisition to the day he transfers his domicile to Luxembourg is subject to a step up. This means that the capital gain subject to tax will be limited to the part of the capital gain between the day of the transfer of domicile and the final sale price. This is an attractive feature of the Luxembourg law allowing individual to mitigate the taxation on any capital gains to be realised on a participation they hold in any companies.
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