On August 22, 2024, Germany’s Federal Fiscal Court (Bundesfinanzhof) published a decision that refocuses attention on the complexities of cross-border taxation, particularly for Luxembourg-based funds investing in Germany....more
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
In a strategic move to support and breathe new life into the housing market, the Luxembourg government has enacted a sweeping set of measures in a law voted on by Luxembourg’s parliament on May 22, 2024. Aimed at both...more
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
On 10 November 2023, the Luxembourg Constitutional Court ruled that the current minimum net wealth tax regime, as applied to Luxembourg resident companies, partially violates the constitutional principle of equal treatment....more
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
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
The Luxembourg Tax Authorities have started to issue late filing penalties for a fixed amount of EUR 10,000 for the non-fulfillment of the reporting obligation regarding real estate levy.
In light of this action,...more
On 7 June 2022, a new Double Tax Treaty (the “DTT”) has been signed between Luxembourg and the United Kingdom (UK) to reflect the most recent OECD tax standard. An additional protocol will replace the tax treaty signed in...more
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
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
7/30/2021
/ Court of Justice of the European Union (CJEU) ,
EU ,
Exemptions ,
Fund Management Companies ,
Fund Managers ,
Income Taxes ,
Investment Funds ,
Investment Management ,
Investors ,
Luxembourg ,
Risk Management ,
Software ,
Tax Authority ,
Tax Litigation ,
Tax Returns ,
Third-Party Liability ,
Value-Added Tax (VAT)
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
6/10/2021
/ Corporate Taxes ,
Digital Services Tax ,
G7 ,
International Tax Issues ,
Investment Funds ,
Luxembourg ,
Multinationals ,
New Rules ,
Tax Haven ,
Tax Liability ,
Tax Rates ,
Tax Reform
On 6 November 2020, Luxembourg and Russia signed a Protocol amending the Luxembourg-Russian Double Tax Treaty.
This new Protocol provides new withholding tax rates and rules for the taxation of dividends and interest...more
On 11 March 2021, the Luxembourg Tax Authorities published a Circular providing guidance on the process for initiating the mutual agreement procedure (“MAP”) under bilateral income tax treaties and explaining the interaction...more
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
4/9/2021
/ Anti Tax Avoidance Directive (ATAD) ,
Borrowers ,
Corporate Taxes ,
Debt ,
EBITDA ,
Income Taxes ,
Interest Rates ,
Luxembourg ,
New Guidance ,
Tax Authority ,
Tax Deductions
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
1/18/2021
/ Corporate Taxes ,
Double Taxation ,
EU ,
Gibraltar ,
International Tax Issues ,
Luxembourg ,
Member State ,
Parent Corporation ,
Subsidiaries ,
Tax Authority ,
Tax Exemptions
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
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
A variety of steps have been taken to accommodate managers working during the lockdown. As at 29 September 2020, these measures are as follows:
1. MORE FLEXIBILITY FOR THE GOVERNANCE OF FUNDS -
On 20 March 2020, the...more
9/30/2020
/ Accounting ,
Anti-Money Laundering ,
Anti-Terrorism Financing ,
Commercial Bankruptcy ,
Coronavirus/COVID-19 ,
CSSF ,
Filing Deadlines ,
Fund Managers ,
Information Technology ,
Investment Firms ,
Investment Funds ,
Investors ,
Liquidity ,
Luxembourg ,
Outsourcing ,
Pension Funds ,
Re-Opening Guidelines ,
Relief Measures ,
Remote Working ,
Reporting Requirements ,
Swing Pricing ,
Time Extensions
A variety of steps have been taken to accommodate managers working during the lockdown. As at 22 June 2020, these measures are as follows:
1. MORE FLEXIBILITY FOR THE GOVERNANCE OF FUNDS...more
6/22/2020
/ Anti-Money Laundering ,
Anti-Terrorism Financing ,
Commercial Bankruptcy ,
Commercial Leases ,
Coronavirus/COVID-19 ,
CSSF ,
Filing Deadlines ,
Information Technology ,
Investment Firms ,
Investment Funds ,
Investors ,
Luxembourg ,
Outsourcing ,
Re-Opening Guidelines ,
Relief Measures ,
Remote Working ,
Reporting Requirements ,
Swing Pricing ,
Time Extensions
A variety of steps have been taken to accommodate managers working during the lockdown. As at 20 May 2020, these measures are as follows:
1. MORE FLEXIBILITY FOR THE GOVERNANCE OF FUNDS -
The increased flexibility for the...more
4/17/2020
/ Commercial Bankruptcy ,
Commercial Leases ,
Coronavirus/COVID-19 ,
CSSF ,
Filing Deadlines ,
Investment Firms ,
Investment Funds ,
Investors ,
Luxembourg ,
Relief Measures ,
Reporting Requirements ,
Swing Pricing
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
Under emergency legislation applicable with immediate effect for three months with a view to contain the rapid spread of COVID-19 in Luxembourg, Luxembourg enacted on 20 March 2020 temporary measures applicable to all...more
3/23/2020
/ Anti-Money Laundering ,
Board Meetings ,
Bondholders ,
Coronavirus/COVID-19 ,
CSSF ,
Emergency Response ,
Investment Funds ,
Luxembourg ,
Shareholders ,
SIFs ,
UCITS