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Corporate Taxes Luxembourg

A&O Shearman

Luxembourg introduces tax relief package for corporates and individuals

A&O Shearman on

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

Goodwin

New Tax Measures Designed to Reinforce Luxembourg’s Attractiveness

Goodwin on

On 17 July 2024, the Luxembourg government introduced, under new Bill n° 8414, a comprehensive legislative package meant to modernise and enhance Luxembourg’s tax system. ...more

White & Case LLP

Luxembourg Tax Update: Key Takeaways from Prime Minister Luc Frieden’s State of the Nation Address

White & Case LLP on

In his State of the Nation Address on June 11, 2024, Luxembourg Prime Minister Luc Frieden introduced several significant fiscal policy initiatives aimed at enhancing the country’s attractiveness to international businesses...more

Goodwin

Pillar Two Implementation in Luxembourg

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On 4 August 2023, Luxembourg published a bill of law (the “Bill”) to transpose the EU directive no. 2022/2523 largely known as the “EU Minimum Tax Directive” or “Pillar Two Directive”, ensuring a minimum global Effective Tax...more

A&O Shearman

Luxembourg tax administration issues guidance on the tax treatment and reporting obligations of reverse hybrid entities

A&O Shearman on

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

Goodwin

Luxembourg Draft Budget Law 2023: The Most Awaited Reverse Hybrid Clarification

Goodwin on

​​​​​​​On 12 October 2022, the finance minister presented the Luxembourg budget bill for fiscal year 2023. For corporate tax payers, and particularly for funds, there is a most welcomed clarification on the scope of the...more

Goodwin

Luxembourg Administrative Court Decision: Parent-Subsidiary Exemption and Account 115 Contributions

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On March 31, 2022, the Luxembourg Administrative Court of Appeal ruled that, in order to determine the minimum acquisition value of a participation for the purposes of the Luxembourg parent-subsidiary exemption, the...more

McDermott Will & Emery

Geschlossene Spezial-Sondervermögen im Immobilienbereich – Top oder Flop?

McDermott Will & Emery on

Ein erster Erfahrungsbericht - Mit Inkrafttreten des Fondsstandortgesetzes (FoStoG) am 2. August 2021 hat der Gesetzgeber das geschlossene Sondervermögen als neue Anlagemöglichkeit im Spezialfondsbereich geschaffen. So...more

Hogan Lovells

Luxembourg is modernising its securitisation law

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The Luxembourg law on securitisation dated 22 March 2004 (the “Securitisation Law”) has been tremendously successful in providing a flexible and secure framework for Luxembourg securitisation vehicles (“SVs”), attracting a...more

Goodwin

Luxembourg: Potential Impacts Of The Global Minimum Tax

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On 4 and 5 June 2021, the Finance Ministers and Central Bank Governors of the G7, joined by the Heads of the International Monetary Fund, World Bank Group, Organisation for Economic Cooperation and Development, and Eurogroup,...more

Goodwin

Luxembourg Tax Authorities Issue Administrative Guidance On Application Of Interest Limitation Rules

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On 8 January 2021, the Luxembourg Tax Authorities published a Circular clarifying the interest limitation rules introduced in Luxembourg legislation in 2018, which implemented the European Union Anti-Tax Avoidance Directive...more

BakerHostetler

[Podcast] When State Tax Agencies Speak from Both Sides of the Mouth

BakerHostetler on

In Wisconsin Department of Revenue v. Deere & Company, the Department of Revenue tried to disallow a dividends received deduction for distributions from a Luxembourg entity despite published guidance conflicting with its...more

Goodwin

Luxembourg: The EU Parent Subsidiary Directive And Gibraltar

Goodwin on

On 1 December, 2020, the Luxembourg tax authorities issued circular L.I.R 147/2, 166/2 and eval. n°63 on the application of EU Directive 2011/96 on the common system of taxation applicable in the case of parent companies and...more

Goodwin

Luxembourg Circular On Interest Limitation Rules

Goodwin on

On 8 January, 2021, the Luxembourg tax authorities published Circular L.I.R. 168bis/1 on interest limitation rules (the “Circular”). The Circular provides much needed clarity to the interest limitation rules which have...more

Goodwin

Luxembourg 2021 Budget: An Overview Of the Main Tax Amendments which Impact The Fund Industry

Goodwin on

The much-awaited Luxembourg state budget for FY 2021 has finally been tabled before the Chamber of Deputies. Delayed due to the ongoing COVID-19 pandemic, the Luxembourg government published bill number 7666 on 14 October...more

Hogan Lovells

Second extension of the temporary measures allowing for virtual meetings of corporate bodies

Hogan Lovells on

The law of 20 June 2020 extended the measures concerning the holding of meetings in companies and other certain legal persons without the physical presence of the participants, initially provided for in the Grand Ducal...more

Skadden, Arps, Slate, Meagher & Flom LLP

EU General Court Rules on Starbucks and Fiat State Aid Cases

On September 24, 2019, the EU General Court (General Court) issued its long-awaited judgments in relation to the appeals brought against two European Commission (EC) decisions of 2015 concluding that tax rulings granted by...more

A&O Shearman

Luxembourg Tax Update: MLI, Exchange of Information, Tax Treaty with France and 2019 Budget Bill

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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

Bennett Jones LLP

Tax Court Affirms Treaty-Based Canadian Holding Structure

Bennett Jones LLP on

The Tax Court of Canada recently held, in Alta Energy Luxembourg SARL v R, 2018 TCC 152, that a Luxembourg S.A.R.L was entitled to treaty benefits on capital gains and that the general anti-avoidance rule ("GAAR") did not...more

Hogan Lovells

Luxembourg - Main New Tax Measures 2018 At A Glance

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On 14 December 2017, the Luxembourg Parliament (Chambre des Députés) approved the draft law (n° 7200) on the 2018 budget including certain tax measures (the "Law"). ...more

Proskauer Rose LLP

UK Tax Round Up - October 2017

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UK Tax News and Developments - Government White Paper on Customs Bill - On 9 October, the Government published a White Paper setting out its approach to the introduction of a new customs and VAT regime after the UK...more

Dechert LLP

Financial Services Quarterly Report - First Quarter 2017: Luxembourg Parliament Adopts 2017 Tax Reform Measures

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The Luxembourg Parliament has adopted new tax measures that affect individual and corporate taxpayers, with effect from 1 January 2017.1 This article summarizes key measures....more

Dechert LLP

Luxembourg Parliament Adopts 2017 Tax Reform Introducing New Tax Measures for Individuals and Corporates

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The Luxembourg Parliament adopted the 2017 tax reform (parliamentary document n°7020) on 14 December 2016 which introduces new tax measures affecting both individual and corporate taxpayers. The publication of the law is...more

King & Spalding

The EC Challenge on Tax Rulings. Why it’s Important that Your Business Acts Now in Relation to EU Challenges to Tax Rulings

King & Spalding on

21 October 2015: Following state aid investigations, the European Commission has ordered Luxembourg and the Netherlands to recover unpaid taxes of €20-30m from each of Fiat and Starbucks. The Commission has confirmed that...more

Sheppard Mullin Richter & Hampton LLP

The European Commission’s New Pandora’s Box – Reopening Final Tax Rulings as a Form of “State Aid”

In Short - The European Commission (Commission) has adopted a decision on 21 October 2015 on the tax rulings – also referred to as “comfort letters” – granted by Luxembourg to Fiat Finance and Trade (FFT) and by The...more

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