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
6/23/2022
/ Cross-Border ,
Cross-Border Transactions ,
Dividends ,
Double Taxation ,
EU ,
European Commission ,
Interest Payments ,
Investors ,
Member State ,
Public Consultations ,
Tax Authority ,
Tax Evasion ,
Tax Fraud ,
Tax Refunds ,
Withholding Tax
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 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