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      Payment institutions (PIs) and electronic money institutions (EMIs) operate in one of the fastest-moving parts of financial services. But with this pace, and as institutions look to scale, there is increasing tax operational and regulatory complexity, across corporate tax, VAT, transfer pricing, reporting and governance.

      The upside? Luxembourg offers powerful incentives for digital and IP-driven business models. Here, we explain how to leverage this and turn compliance into advantage.


      A demanding tax landscape

      The tax obligations on PIs and EMIs are varied and complex. For example, did you know that… 

      • Luxembourg PIs and EMIs can face 10+ distinct tax obligations depending on their business model, group structure and cross border footprint – from annual corporate tax returns and VAT to FATCA/CRS classification and reporting, Pillar Two registration, assessment and compliance, and CSSF AML tax indicators designed to identify and mitigate risks of aggravated tax fraud and tax evasion?
      • Tax authorities and the financial regulator are intensifying scrutiny – leading to more audits and on site inspections particularly focusing on the company’s tax processes?
      • Regulators expect a documented, end to end tax governance framework that covers all applicable tax obligations, relevant roles, controls and evidence?


      Beyond obligations: 

      Luxembourg’s tax incentives for digital finance 

      However, notwithstanding the challenges, did you also know that Luxembourg offers highly attractive tax incentives for innovative, IP‑driven businesses – such as the intellectual property (IP) regime and investment tax credits for digital transformation?

      As part of the Luxembourg IP regime, a Luxembourg company can benefit from an 80% tax exemption on income and capital gains derived from eligible intellectual property assets such as software or patents. Such IP assets must have been developed or improved after 31 December 2007 as part of research and development activities performed by the Luxembourg company. For technology-led PIs/EMIs, this can materially reduce the effective tax rate on eligible, value-creating assets. We can help you assess eligibility, ring-fence qualifying income and set up robust tracking.

      Luxembourg’s Investment Tax Credit for digital transformation – and, where relevant, eco‑transition – covers eligible investments and qualifying operating expenses tied to digital and ecological/energy transition projects, offering a credit of up to 18% that directly reduces a company’s corporate income tax liability. We can guide you from eligibility scoping and certification to claiming and audit readiness.

      Why tax governance is a strategic lever for PIs and EMIs

      Managed correctly and taking advantage of available incentives, tax governance is more than compliance: it mitigates risk, enhances efficiency and enables your strategic growth. A robust tax governance framework brings structure, ownership and transparency to how taxes are managed – reducing risk, supporting better decisions and giving boards, investors and regulators confidence that tax is handled as a strategic, well-governed function.

      At KPMG, our technology-enabled approach consolidates tax-related data, deadlines and processes into a single real-time dashboard, so you can monitor obligations, manage risk and streamline collaboration across Finance, Tax and Compliance.

      Role-aware workflows orchestrate tasks (e.g. corporate tax return steps, approvals and document packs), track progress and audit trails, and surface what’s due this week or overdue, reducing manual follow-ups and improving accountability.

      For PIs and EMIs this brings the following advantages:

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      Confidence with regulators and investors

      A clear audit trail for policies, decisions and reporting. 

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      Efficiency at scale

      Harmonized processes across entities and jurisdictions that reduce ad hoc fixes and rework.

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      Strategic value

      Tax embedded into pricing, product and expansion decisions (including cross-border footprints and IP strategy).



      How KPMG can help – pragmatic steps that deliver


      By harnessing technology to increase automation and always-on control, KPMG can help you manage tax governance and compliance in a way that is both practical and value-adding, including: 

      • Rapid tax health check

        Focused review of your current obligations, processes and documentation to identify gaps and quick wins – so you know where to prioritize. 

      • Alignment and design

        A defined governance model that fits your license, footprint and growth plan, with clear roles, policies, controls and escalation paths. 

      • Optimized processes

        Implementation of automated workflows, dashboards and documentation hubs to move from reactive to proactive governance, backed by templates and training.



      Make your next move

      If you’re building a scalable payment or e-money platform, now is the time to upgrade tax from “necessary” to “advantage.”
      KPMG Luxembourg’s Financial Services Tax team helps you:

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      Meet core obligations with confidence and speed

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      Unlock Luxembourg’s IP and digital transformation incentives

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      Stand up a robust, automated tax governance model that scales with you.


      Our experts

      Daniel Rech

      Partner, Tax Transparency Services

      KPMG in Luxembourg

      Edouard Fort

      Partner, Tax

      KPMG in Luxembourg


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