OpenLux: što javni registar otkriva o luksemburškim tvrtkama

In February 2021, Le Monde published OpenLux, a cross-border investigation into companies registered in Luxembourg. The project examined information available through Luxembourg’s public Trade and Companies Register, known as the Registre de commerce et des sociétés (RCS), and used that material to map ownership structures, corporate activity and the movement of assets through the country.

OpenLux was produced by Le Monde with media partners in several European countries. Its reporting focused on what could be established from company records and related documents. The investigation did not treat the existence of a Luxembourg company as proof of wrongdoing: companies may be established there for lawful business, investment, financing or administrative reasons.

What the public register contains

The RCS contains records concerning companies and other legal entities registered in Luxembourg. Depending on the entity and the available filing, these records can include a company’s name, legal form, registered office, managers, dates of incorporation, annual accounts and information about ownership or controlling interests.

For investigative journalists, the value of the register lies in connecting individual records. A single filing may reveal little, while a comparison of many filings can show recurring directors, shared addresses, links between companies and changes in ownership over time. Those connections still require verification against other records and reliable reporting.

How OpenLux used the data

Le Monde reported that its investigation assembled and analysed a large body of Luxembourg corporate data. Journalists studied companies, their filings, directors, shareholders and reported assets, then followed selected cases across national borders. The work combined data analysis with document review and reporting on people, businesses and properties identified in the records.

The project also placed Luxembourg records in a wider European context. Corporate structures often involve entities and assets located in more than one country, so a register in one jurisdiction may need to be compared with land records, court documents, corporate filings and reporting from another. OpenLux illustrates how public records can become more informative when examined together rather than separately.

Findings reported by Le Monde

• A large corporate population. The investigation identified more than 124,000 companies in the data it examined, including many holding companies whose principal purpose was to own assets or interests in other entities.
• Substantial assets recorded in Luxembourg. Le Monde reported that the companies examined declared at least €6 trillion in assets. This figure reflected the values recorded in company filings and should not be read as a measure of Luxembourg’s domestic economy.
• International ownership. The reporting found that a large majority of the companies studied had owners or controlling interests located outside Luxembourg. This reflected the country’s role as a major international financial and corporate centre, but did not by itself establish unlawful conduct.
• Use of holding structures. The records showed how companies could be used to hold shares, real estate, intellectual property and other assets. In some cases, several entities were placed in succession, making the structure more difficult for an outside observer to understand.
• Connections across sectors and countries. The investigation traced structures involving multinational companies, investment vehicles, property holdings and wealthy individuals. The published cases differed from one another and cannot be treated as evidence that all companies using similar structures acted in the same way.

These points describe the findings as presented by Le Monde and its partners. They are not a general conclusion that Luxembourg companies, holding companies or cross-border ownership arrangements are illegal. The legal and tax consequences of a structure depend on its documents, the jurisdictions involved and the applicable rules.

Why the investigation mattered

OpenLux drew attention to the difference between formal transparency and practical transparency. A register may be public, yet still difficult to use when information is spread across thousands of filings, presented in different formats or connected to companies in other countries. Data access alone does not automatically make ownership structures easy for citizens to understand.

The investigation also showed the importance of distinguishing between a documented fact and an interpretation. A company address, a director’s name or a reported asset can help establish a connection. It does not, without further evidence, prove tax evasion, corruption, money laundering or another offence. Responsible investigations therefore compare records, seek responses from the people and organisations concerned and explain the limits of the available evidence.

What the register cannot establish on its own

• A company’s registration does not prove that it has committed an offence.
• A listed director or shareholder may not be the person who ultimately controls every decision unless the available evidence supports that conclusion.
• An address shared by several companies may indicate a corporate or administrative service, but it is not by itself proof of a fictitious company.
• Figures in annual accounts are reported values prepared under applicable accounting rules; they are not automatically independent valuations.
• The absence of a document from a public register does not necessarily prove that an event or relationship did not exist.

Sources and editorial limits

This article is based on the OpenLux investigation published by Le Monde in 2021 and on the Luxembourg Trade and Companies Register described in that reporting. The original investigation was carried out with international media partners and included data analysis, documentary research and requests for comment.

OpenLux is a source for understanding corporate structures, not a complete record of every financial relationship or transaction. Registers change, filings may be incomplete or amended, and the meaning of a document depends on its legal and factual context. Any claim about an individual company or person should therefore be checked against the original filing and additional independent sources.

Napomena uredništva: Ovaj pregled sažima javno poznato istraživanje i upućuje na izvorno novinarsko djelo. Ne iznosi nove optužbe.