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Proposed Amendments to Pillar Two Law in Luxembourg

On 12 June 2024, Luxembourg published a bill of law amending the law of 22 December 2023 (the Pillar Two Law[1]) implementing EU directive no. 2022/2523, largely known as the “EU Minimum Tax Directive” or “Pillar Two...more

Horizon Scan for Private Investment Funds - May 2024

Welcome to the second edition of our Horizon Scan for 2024: key recent and expected funds, regulatory, and tax developments to look out for. As before, we focus on the most important developments and changes that we expect to...more

Pillar Two Implementation in Luxembourg

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 New Direction for ATAD III Proposal?

​​​​​​​Further to the request of the European Parliament for concerted EU action, the European Commission issued on 22 December 2021 a proposal for a Council Directive laying down rules to prevent the misuse of shell entities...more

Public Consultation on a Common EU-Wide System for Withholding Tax Claims on Dividend and Interest Payment

The EU Commission published a public consultation based on its initiative to introduce a common EU-wide system for withholding tax on dividend or interest payments, which includes a system for tax authorities to exchange...more

Unshell Directive Proposal: How to Navigate New Substance Requirements

On 22 December 2021, the European Commission presented a proposal for a new directive to fight against the misuses of shell entities for improper tax purposes. This proposal has been issued to ensure that entities in the...more

European Commission’s Proposal to End the Misuse of Shell Entities for Tax Purposes within the EU

BACKGROUND - On 22 December 2021, the European Commission presented a proposal for a new directive to fight against the misuses of shell entities for improper tax purposes. This proposal has been issued to ensure that...more

New Developments on the VAT Exemption for Fund Management Services

On 17 June 2021, the Court of Justice of the European Union (CJEU) rendered two decisions about the application of the VAT exemption for management services provided in article 135 (1) (g) of the EU VAT Directive and...more

Luxembourg: New Rule Disallowing Deduction On Payments To EU Non-cooperative Countries

Luxembourg has introduced new legislation disallowing the deduction of interest and royalties owed by Luxembourg corporate taxpayers to associated enterprises established in a jurisdiction included in Annex I of the European...more

Luxembourg: The EU Parent Subsidiary Directive And Gibraltar

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

Luxembourg Adopts Draft Bill Introducing Defensive Tax Measures for EU List of Non-Cooperative Jurisdictions

On 25 March 2020, the Luxembourg Government adopted a draft bill introducing new defensive measures denying the tax deduction of interest and royalty payments made to a related entity located in a blacklisted...more

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