On July 17, 2024, the Luxembourg Minister of Finance submitted Bill of Law #8414 to the Luxembourg Parliament. The Bill proposes a series of tax measures aiming to make Luxembourg a more attractive place to work, do business...more
On 9 June 2023, the Luxembourg tax administration (the LTA) issued circular L.I.R. n°168quater/1 (the Circular) providing long-awaited guidance on the application of article 168quater of the Luxembourg Income Tax Law (the...more
A new requirement to inform individuals of the exact personal data to be shared with the Administration des Contributions Directes.
The Luxembourg law of 18 December 2015 on the automatic exchange of financial account...more
2023 is set to be a year of change for the global tax landscape. After many years of negotiation, development and consultation, implementation of the OECD’s Pillar One and Pillar Two reforms to international taxation is now...more
On 8 November 2022, in the case Luxembourg and Fiat Chrysler Finance Europe v Commission, the Court of Justice of the European Union (the Court) annulled the judgment of the General Court as well as the decision of the...more
More than four yeas after the announcement of negotiations, the new tax treaty between Luxembourg and the United Kingdom was finally signed on 7 June 2022, together with a Protocol adding further detail.
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More than four years after the announcement of negotiations, the new tax treaty between Luxembourg and the United Kingdom was finally signed on 7 June 2022, together with a Protocol adding further detail. As expected, the new...more
Part II UCIs, SIFs and RAIFs in the form of an SA, SCA or Sàrl must declare by 31 May 2022 and pay by 10 June 2022 to the Luxembourg tax authorities a 20% tax on income and gains derived from Luxembourg real estate. Part II...more
On 9 February 2022, the Luxembourg parliament adopted law no. 7825 (Law) amending, among others, the Luxembourg act dated 22 March 2004 on securitisation, as amended (Securitisation Act 2004) to Parliament. ...more
As previously announced, in the context of its ongoing fight against tax evasion and despite the as yet unknown impact of ATAD 1 and ATAD 2 on the EU market, on 22 December 2021 the European Commission published a proposed...more
On 20 December 2021, the OECD published keenly awaited model rules designed to implement Pillar Two of its ambitious plans to reform international taxation. ...more
As announced in October, new tax measures are included in the Luxembourg budget law for 2021 which was adopted by the Luxembourg Parliament on 17 December 2020 (the Law). The Law will be published in the coming days.
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Whilst all our attention and energy are focused on Covid-19, other important developments continue that require your early attention. Bill n° 7465 implementing Council Directive (EU) 2018/822 of 25 May 2018 amending Directive...more
Whilst all our attention and energy are focused on the Covid-19 situation, other important developments continue that require attention.
On 30 March 2020, the Luxembourg Government introduced a draft of law N°7547 before...more
Luxembourg Minister of Finance Pierre Gramegna has presented the Luxembourg government’s budget bill for year 2020 to the Luxembourg Parliament today (the Budget 2020 Bill). ...more
The law dated 7 March 2019 approving the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (Multilateral Instrument or MLI) was published in the Luxembourg Mémorial...more
Following decisions of the Court of Justice of the European Union and of the French Conseil d’Etat dealing with virtual currencies (e.g., bitcoin, ethereum), the director of the Luxembourg direct tax administration clarified...more
As recently announced, the French and Luxembourg governments are finalising a new double tax treaty between the two countries (the «DTT»).
We outline below the key revisions and their potential impact.
1. Withholding...more
The Luxembourg Government has, on 4 August 2017, submitted a bill1 to Parliament for the reintroduction of a regime of taxation of intellectual property (IP) rights in Luxembourg.
The new regime is intended to replace the...more
On 30 September 2016, the Luxembourg indirect tax administration (LTA) issued a circular n°781 confirming that director fees are subject to VAT (the Circular). As reported in our previous e-alert on this matter circulated in...more
On 14 July 2016, the Luxembourg Parliament approved bill of law n°6929 introducing a new type of Luxembourg investment fund: the reserved alternative investment fund (RAIF - or fonds d’investissement alternatif réservé,...more
The Luxembourg government announced yesterday the key elements of a tax reform that should apply as from fiscal year 2017. Companies will generally benefit from a reduced corporate income tax rate, whilst minimum net wealth...more
The Luxembourg indirect tax administration is reported to have confirmed that director fees are subject to VAT. This is in line with the Luxembourg VAT law and the position of the European Commission on this matter....more
On 28 January 2016, the European Commission published the proposal for a so-called Anti-Tax Avoidance Directive. The Directive applies to all taxpayers which are subject to corporate tax in an EU Member State, including...more
3/24/2016
/ BEPS ,
Controlled Foreign Corporations ,
Court of Justice of the European Union (CJEU) ,
EBITDA ,
EU ,
EU Directive ,
European Commission ,
Exit Tax ,
GAAR ,
Luxembourg ,
OECD ,
Tax Avoidance
On 15 October 2014, the Luxembourg Minister of Finance submitted the draft budget for 2015 (the Budget Bill) to the Parliament. The Budget Bill does not overhaul the Luxembourg corporate tax environment, however, it proposes...more