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Luxembourg capitalisation contract simulator: savings, estate planning and security
The Luxembourg capitalisation contract combines two features that nothing else brings together: from the French capitalisation contract, transferability by gift and ownership by a company subject to corporation tax; from Luxembourg, protection with no ceiling and a wider investment universe. What most people do not know is that it is the vehicle of choice for family holding companies wishing to invest significant cash in diversified assets while keeping maximum legal security.
Keeping the contract's tax start date, in full ownership or through split of ownership
Security Triangle and Super Privilege: protection with no ceiling, where France stops at €70,000
To invest the cash of a company subject to corporation tax in dedicated funds, individual securities and multi-currency private equity
The simulator
Simulate your Luxembourg capitalisation contract
Select your country of tax residence: the projection applies its tax on withdrawals (Luxembourg is neutral). Your data is neither stored nor transmitted.
Luxembourg capitalisation contract simulator
The Luxembourg capitalisation contract: taxation according to your country of residence, estate planning and the Security Triangle.
Indicative calculation, based on 2026 rules and the assumptions entered above.
Why
Why combine capitalisation and Luxembourg
Most business owners who build up cash in a holding company leave it idle in a current account or put it into a few in-house products offered by their bank. That is a considerable opportunity cost, and an exposure to counterparty risk that is rarely measured. The Luxembourg capitalisation contract addresses exactly this blind spot by bringing together two building blocks that are usually kept apart.
On the capitalisation side: transferability by gift while keeping the contract's tax start date, and possible ownership by a legal entity subject to corporation tax. On the Luxembourg side: asset protection (your assets segregated off the insurer's balance sheet, Super Privilege with no ceiling) and an investment universe much wider than the French offering — dedicated funds, individual securities, private equity, multi-currency management.
The result is the tool of choice for family holding companies wanting to invest significant cash in diversified, secure assets while preparing to pass the holding company's shares — and therefore, indirectly, the contract — to the next generation. It is a structuring mechanism, not a mere investment.
What the calculation shows
The 3 levers reserved for wealth held through companies
A company subject to corporation tax — a holding company, an SCI subject to corporation tax — cannot take out assurance-vie, but can hold a capitalisation contract. In the Luxembourg version, surplus cash is invested in dedicated funds and individual securities while remaining legally separate from the insurer's balance sheet thanks to the Security Triangle. For a business owner who has sold their company or built up cash, it combines genuine diversification with protection that has no ceiling, whereas the French guarantee is limited to €70,000.
The Luxembourg capitalisation contract is part of an indirect estate planning strategy : by giving the holding company's shares (in full ownership or through split of ownership) to the next generation, you also indirectly pass on the contract it holds. How this fits with the parent-subsidiary regime, contribution and sale (Article 150-0 B ter) and the gift of shares is designed case by case. This is precisely where wealth engineering creates the most value — and where standard bank distribution is absent.
The Luxembourg contract gives access to assets unavailable in the French offering: dedicated internal funds run by the manager of your choice, specialised insurance funds, individual securities, direct bonds, private equity, and management in several currencies. For a holding company with international business or holdings, the multi-currency dimension neutralises currency risk, and a Lombard loan secured on the contract generates liquidity without disinvesting or triggering a withdrawal. No conventional cash investment offers this flexibility.
Case study
Case study: Jean-Marc, 59, a business owner who has sold his company, Luxembourg contract held by his holding company
Jean-Marc sold his business and placed €1,200,000 of cash in his family holding company subject to corporation tax. Rather than leave it idle, he takes out a Luxembourg capitalisation contract held by the holding company, invested in multi-currency dedicated funds at 4.5% net, with a view to gradually passing it on to his three children. Here is the projection:
| Indicator | Cash in a current account | Luxembourg capitalisation in a holding company | Contribution |
|---|---|---|---|
| Projected capital after 12 years | ≈ €1,200,000 (eroded by inflation) | ≈ €2,040,000 | +€840,000 in potential |
| Asset protection | Bank counterparty risk | Security Triangle, no ceiling | Maximum security |
| Diversification | Virtually none | Dedicated funds, individual securities, private equity | Full universe |
| Passing on to the children | Via taxed sale / liquidation | Gift of holding company shares (split of ownership) | Tax start date preserved |
Cash that was sitting idle in a current account — exposed to inflation and counterparty risk — becomes a diversified asset, protected with no ceiling and part of an estate planning approach. The projected capitalisation is purely illustrative, but the gap in potential compared with idle cash is structural.
By gradually giving the bare ownership of his holding company's shares to his three children, Jean-Marc indirectly passes on the contract at a value reduced by the usufruct scale, while keeping control and the income. This is the typical combination — holding company, Luxembourg capitalisation, split of ownership — which cannot be improvised and is built with an adviser.
In practice
The top tier of a holding company strategy
This simulator applies French taxation to a withdrawal after 8 years (Luxembourg being tax-neutral) and gives an order of magnitude for the capital. But the Luxembourg capitalisation contract is more than these figures: it only makes sense within a holding company structure, combined with the parent-subsidiary regime, contribution and sale (150-0 B ter) and the gift of shares. It is a building block of wealth engineering, not an off-the-shelf product.
Balmont Conseil is a wealth management advisory firm based in Lyon, a member of ANACOFI-CIF, with no capital ties to any bank. Open architecture allows us to select the Luxembourg insurance company and the investment options from among our partners, and to build the holding / contract / succession structure in your interest. Let's book an appointment to structure the investment of your company's cash.
Frequently asked questions
What clients ask us.
Why hold a Luxembourg capitalisation contract in a holding company?
Because a company subject to corporation tax cannot hold assurance-vie, but it can hold a capitalisation contract. The Luxembourg version adds protection with no ceiling (Security Triangle, Super Privilege) and a wider investment universe (dedicated funds, individual securities, private equity, multi-currency). For a business owner who has sold their company or built up cash in a holding company, it is the way to put that cash to work in a diversified, secure manner, rather than leaving it idle in a current account.
How is this contract passed on when it is held by a company?
It is passed on indirectly, through the holding company's shares. By giving all or part of the company's shares (in full ownership or with split of ownership into bare ownership / usufruct) to your children, you also pass on to them the contract the holding company holds. The usufruct scale reduces the taxable base according to your age, and the contract's tax start date is preserved. How this fits with the parent-subsidiary regime and contribution and sale (150-0 B ter) is designed case by case.
Is the taxation different from the French version?
Luxembourg applies tax neutrality: it levies no tax of its own. For a structure that is tax resident in France, French taxation therefore applies — that of a capitalisation contract held by a legal entity subject to corporation tax, namely a flat-rate annual tax on a notional base, adjusted on withdrawal. The Luxembourg version brings no tax advantage in itself: its strengths are legal security with no ceiling and the investment universe, not taxation.
From what amount does this solution make sense?
Like Luxembourg assurance-vie, the Luxembourg capitalisation contract makes sense from around €250,000, and even more so above that. It is aimed at family holding companies and business owners with significant company cash to diversify and secure. Below this threshold, a French open-architecture capitalisation contract generally meets the need without the entry ticket and costs of a Luxembourg structure.
How does Balmont Conseil differ from a bank adviser for this kind of structuring?
Balmont Conseil is a wealth management advisory firm based in Lyon, a member of ANACOFI-CIF, with no capital ties to any bank. Structuring a holding company's cash through a Luxembourg capitalisation contract — with a parent-subsidiary set-up, contribution and sale of shares (apport-cession) and gifts of shares — is a matter of wealth engineering, not product distribution. A bank adviser does not offer this structure. Open architecture allows us to select the insurance company and the investment options from among our partners and to build the structure that serves your interest.
