InvestigationIn the 2010s, Luxembourg attracted thousands of companies and celebrities, who came to benefit from a very advantageous tax regime for income arising from intellectual creation.
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Once upon a time there was a French Michelin-starred chef, a Colombian pop star and a Croatian international footballer. All three lived on their talent and fame. Their name had become a brand, which generated so much profit that they had the same idea: to open a company in Luxembourg to pay less taxes.
Stories like theirs, OpenLux documents are full of them. Because, in the 2010s, Luxembourg was a real promised land for intellectual property. Trademarks, patents, image rights, cinema adaptation rights, musical copyrights: in a few years, intangible assets from around the world have been transferred on a massive scale to Luxembourg companies. Not to be really managed on the spot, because these companies were for the most part empty shells. But because, like other tax havens, Luxembourg created in 2008 a special and ultra-advantageous tax regime for income relating to “intellectual creation”: they are taxed at less than 6%, ie two times less than in France.
Like Malta, Cyprus, Ireland, or even Belgium, Luxembourg has this regime to attract to its soil companies which invest in research and innovate, and a highly qualified population. But this Intellectual Property Box (“Patent box”) was quickly diverted from its use: thousands of companies have used it to optimize their taxes, by relocating the profits from intellectual property without moving the activity and the corresponding workforce. Pushed by their tax advisers, rich and famous individuals have also plunged into this generous tax loophole, yet designed for businesses.
The detours of Yannick Alléno
This is the case with Yannick Alléno. In 2010, the famous French cook still officiates at the Parisian palace Le Meurice. He reinvents local cuisine, sublimating mackerel in white wine and egg mayo. Awarded three Michelin stars, he has also started to lend his name and his recipe book to restaurants around the world, from Courchevel to Marrakech, via Dubai. In return, these prestigious addresses pay him royalties. But instead of arriving in his French company, Yuzu, the money makes a detour via Citrus Junos, its Luxembourg twin, which in Latin designates the same Japanese citrus fruit. As this company owns all the brands in the Alléno universe, it can benefit from a nice tax reduction.
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