Guide to the Foreign Direct Investment Survey 2025

March 2026

TABLE OF CONTENTS

1.1 Motivations ................................................................................................................... 3
1.2 Scope ............................................................................................................................ 3
1.3 Confidentiality .............................................................................................................. 3
1.4 Contact with the BCL ................................................................................................. 4
1.5 Data Transmission ..................................................................................................... 4
2 DEFINITIONS 6
2.1 Foreign Direct Investment ........................................................................................ 6
2.2 Foreign Direct Investor .............................................................................................. 6
2.3 Direct Investment Enterprise .................................................................................... 6
2.4 Reverse Investment .................................................................................................... 6
2.5 Foreign Direct Investment Relationship .................................................................. 7
2.6 Resident ........................................................................................................................ 7
2.7 Non-resident ................................................................................................................. 7
2.8 Direct Link ................................................................................................................... 7
2.9 Indirect Link ................................................................................................................. 8
2.10 Subsidiary .................................................................................................................... 8
2.11 Affiliate ......................................................................................................................... 8
2.12 Branch .......................................................................................................................... 8
2.13 Participation ................................................................................................................. 8
2.14 Ultimate Shareholder .................................................................................................. 9
3 EXPLANATORY NOTES ON THE QUESTIONNAIRES 10
3.1 Reporting Period ....................................................................................................... 10
3.2 Shareholding/Participation Chart ............................................................................. 10
3.3 Monetary Evaluation ................................................................................................. 11
3.4 Data Valuation .......................................................................................................... 11
3.5 Exceptional Items .................................................................................................... 11
3.6 Exemption (Questionnaire No. 4) ............................................................................. 12

PRESENTATION

1.1 Motivations

The Banque centrale du Luxembourg conducts this survey on an annual basis to collect information on investments by any foreign investor in your company and your own investments in non-resident enterprises. These data are essential for us to fulfill Luxembourg's statistical obligations to international organizations, to conduct economic analyses, to compile the global external position accounts, and finally to measure the growth and impact of investments over time.

1.2 Scope

The survey applies to:

• any credit institution established in Luxembourg and incorporated under Luxembourg law, where a non-resident holds at least 10% of the ordinary shares or voting rights;
• any credit institution established in Luxembourg and incorporated under the law of its country of origin;
• any credit institution established in Luxembourg and incorporated under the law of its country of origin, which holds at least 10% of the ordinary shares or voting rights of an enterprise established outside the national territory;
• any credit institution established in Luxembourg and incorporated under Luxembourg law, which owns an enterprise established outside the national territory.

1.3 Confidentiality

This survey is conducted under the framework of the Law of 23 December 1998 on the monetary status and the Banque centrale du Luxembourg (Art. 32, 2° and Art. 33). The information collected will be used for statistical purposes, with results published only in aggregated form to avoid the disclosure of individual data.

1.4 Contact with the BCL

For any additional information, please contact the BCL by sending an email to fdi@bcl.lu.

1.5 Data Transmission

The duly completed questionnaires must be sent to the BCL before 11 September 2026.
If your institution experiences delays, we invite you to inform us before this date, via a duly motivated letter.

FDI 2025 Data Transmission Method:
Documents related to the survey can be submitted to the BCL via the following transmission methods:

• preferably via secure channel using the electronic transmission means provided by SOFiE (OTX channel) or E-file (miscellaneous correspondence).
  It is imperative to respect the following file naming structure:
  OTXREP-Bnnn-BOP_FDI_2025_Bnnn_20260911_001.xls where nnn corresponds to the BCL number of the reporting credit institution.
• by email (unsecured transmission) to fdi@bcl.lu
  mentioning in the subject line: BCL No – FDI 2025.

FDI 2025 Data Formatting:
Reporting for the survey must be submitted in MS Excel file format. Unless prior agreement is obtained, other file formats will no longer be accepted. Only exception: the chart from sheet 1-2 of questionnaire 1 can be sent in PDF format in a separate file, if the reporter cannot include it in questionnaire 1. The file must respect the file naming structure described above.

FDI 2025 Data Quality:
The FDI 2025 data reported should, if possible, correspond to the reporter's FINREP version D data of December 2025.
In the absence of FINREP version D reporting, the FDI 2025 data will be compared to the reporter's FINREP version N data of December 2025.
In the absence of FINREP version D or N reporting for December 2025, the FDI 2025 data will be compared to the data published in the reporter's 2025 annual report. For residual cases, the comparison of FDI 2025 data will be based on data available at the level of the reporter's BCL statistical reporting S1.1-6 of December 2025.

2 DEFINITIONS

In reference to the recommendations of international institutions (IMF, OECD), the basic concepts of the survey are defined as follows:

2.1 Foreign Direct Investment

The set of resources (capital contributions, reinvested earnings, loans, endowments) that a direct investor leaves at the disposal of affiliated enterprises with which it has a direct investment relationship. Direct investment therefore refers to "investments made by a resident entity of an economy (the direct investor) with the aim of acquiring a lasting interest in an enterprise resident in another economy (the direct investment enterprise). By lasting interest, it is meant that there is a lasting relationship between the direct investor and the direct investment enterprise and that the investor exercises significant influence on the management of the enterprise. Direct investments include not only the initial transaction, which establishes the relationship between the investor and the enterprise, but also all subsequent transactions between them and between affiliated enterprises, whether or not they are incorporated and thus have separate legal personality" (IMF, Balance of Payments Manual, 5th edition).

2.2 Foreign Direct Investor

A direct investor is an enterprise, resident in an economy, which holds directly or indirectly at least 10% of the capital of a non-resident direct investment enterprise.

2.3 Direct Investment Enterprise

A direct investment enterprise is an enterprise, resident in an economy, in which an enterprise, resident in another economy, holds at least 10% of the capital, whether directly or indirectly.

2.4 Reverse Investment

This refers to financing that flows in the opposite direction to influence and control, i.e., when the direct investment enterprise itself holds a participation in its direct investor. These reverse investments concern only cases where the share of voting rights acquired by a direct investment enterprise in its direct investor is less than 10% (a reverse participation of more than 10% would, on the other hand, establish a direct investment relationship proper).

2.5 Foreign Direct Investment Relationship

Any direct or indirect link between a resident of Luxembourg and an enterprise established in a foreign territory or between a non-resident established outside the territory of Luxembourg and an enterprise established in the national territory, which allows this resident or non-resident - the direct investor - to have significant influence in the management of the concerned enterprise - the direct investment enterprise - and which testifies to a lasting interest of the direct investor in said enterprise. There is a presumption of the existence of a direct investment relationship when the direct investor holds at least 10% of the capital or 10% of the voting rights.

2.6 Resident

• any legal person of national public law and all its services on national territory;
• any legal person of national private law, for the activities of its registered office, its subsidiaries, affiliates, and branches established on national territory;
• any legal person of foreign law, for the activities of its branches and operating headquarters established on national territory.

2.7 Non-resident

Any natural person or legal person who is not considered a resident of Luxembourg.

2.8 Direct Link

A direct link is said to exist when a foreign direct investor directly holds a direct investment enterprise.

2.9 Indirect Link

An indirect link is said to exist when a foreign direct investor holds a subsidiary or affiliate which itself holds directly or indirectly a direct investment enterprise. Example:
75% 25%
Direct link of the resident credit institution with Enterprise A: 75% Indirect link of the resident credit institution with Enterprise B: 75% x 25% = 18.75%

2.10 Subsidiary

An enterprise with legal personality where the direct investor:

• owns more than 50% of the ordinary shares or voting rights;
• has the right to appoint or remove the majority of the members of the Board of Directors.

2.11 Affiliate

An enterprise in which the direct investor owns between 10% and a maximum of 50% of the ordinary shares or voting rights or holds effective decision-making power in the management of this enterprise.

2.12 Branch

An enterprise that does not have legal personality according to the law of the host country. It can be a permanent establishment or an office, a partnership, or a joint venture.

2.13 Participation

It is presumed to constitute a participation, the holding of a category of shares or voting rights representing at least 10% of the capital or share capital of the direct investment enterprise. Resident Credit Institution A B

2.14 Ultimate Shareholder

The parent company that has ultimate control of the enterprise in question, i.e., the institutional unit located at the start of the ownership chain, which is itself not controlled by any other institutional unit.

3 EXPLANATORY NOTES ON THE QUESTIONNAIRES

The survey consists of four different questionnaires:

• Questionnaire No. 1: General information on the resident credit institution
  This questionnaire must be returned to the BCL even if your institution does not fall within the scope of the survey.
• Questionnaire No. 2: Shareholding
  This questionnaire must be completed if your institution is held directly or indirectly by one or more non-resident shareholders or if its parent company is established abroad (as many questionnaires as there are links).
• Questionnaire No. 3: Participations
  This questionnaire must be completed if your institution holds directly or indirectly one or more subsidiaries or branches established abroad (as many questionnaires as there are links).
• Questionnaire No. 4: Exemption
  This questionnaire is intended for any credit institution that does not meet the survey criteria. In this specific case, two documents must be returned:
  Questionnaire No. 1 (with the exception of sections D and E) + Questionnaire No. 4 duly completed and signed.

3.1 Reporting Period

The data provided must relate to the situation as of 31 December 2025, or failing that, the situation at the end of the accounting period (to be specified).

3.2 Shareholding/Participation Chart

Questionnaire No. 1, Section C: this section must, in all cases, be completed and returned to the BCL, even if the resident credit institution does not meet the survey criteria. An example of the presentation of a chart is included in the questionnaire.

This part consists of a combined chart of:

• the shareholding structure - national and international - direct and indirect (going up to the ultimate shareholder);
• the participation structure - national and international - direct and indirect of the resident credit institution.

3.3 Monetary Evaluation

All data must be communicated in EUR. If accounting information is available in another currency, it must be converted into EUR at the exchange rate in effect on the last day of the fiscal year, rate published by the European Central Bank and available at the following link:
www.ecb.europa.eu/stats/policy_and_exchange_rates/euro_reference_exchange_rates/

3.4 Data Valuation

The following principles must be respected:

• Figures must be transmitted on a non-consolidated basis.
• Data relating to the equity of the resident credit institution must be submitted strictly according to the IFRS accounting standard.
• Regarding participations, please specify the valuation method used to establish their net book value (market value, historical cost, acquisition price, fair value).
• Net book value (subsidiary or affiliate): net book value as recorded in the assets of the balance sheet of the resident credit institution at the end of the fiscal year.
• Net assets (branch): Evaluation of equity by the total amount of the balance sheet assets (after depreciation) minus the required liabilities (debts and provisions).

3.5 Exceptional Items

If during the fiscal year, the credit institution recorded exceptional expenses and/or income, it is necessary to specify the amount and the reason.
Indeed, since direct investment income is calculated using the "current operations" method (See OECD Manual "International Direct Investment Definition, 4th Edition"), it is necessary to be able to exclude certain exceptional items, income or expenses (e.g., capital gains from disposals, debt forgiveness, etc.). For more details, please refer to points 208 and 209 (page 74) of this Manual.

3.6 Exemption (Questionnaire No. 4)

This questionnaire must be completed when the credit institution has no foreign shareholding or foreign participation greater than or equal to 10%. It must state the reason why said credit institution does not fall under the criteria of the foreign direct investment survey. For your information, credit institutions in this case are nevertheless required to also complete questionnaire No. 1 (with the exception of sections D and E).