The implementation of the Organisation for Economic Co-operation and Development’s (OECD’s) Pillar II rules in Europe, and in the Luxembourg law on 22 December 2023 (the Pillar II Law) in particular, has been a major...more
4/10/2025
/ EU ,
Fund Managers ,
International Tax Issues ,
Investment Funds ,
Luxembourg ,
Multinationals ,
New Legislation ,
New Regulations ,
OECD ,
Pillar 2 ,
Popular ,
Tax Planning ,
Taxation
On 29 January 2025, the Luxembourg tax authorities published Circular L.I.R. n° 164/1 (Circular), which replaces the previous circular L.I.R. n° 164/1, dated 23 March 1998. The Circular updates the rules related to interest...more
Among other tax incentives for individual and corporations, the Luxembourg Parliament adopted on 11 December 2024 an amendment to the interest deduction limitation rule via the introduction of the concept of a single-entity...more
Welcome to the third 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...more
11/1/2024
/ Corporate Governance ,
Disclosure Requirements ,
Economic Sanctions ,
EU ,
Financial Crimes ,
Fund Managers ,
MiFID II ,
Packaged Retail And Insurance-Based Investment Products (PRIIPS) ,
Private Funds ,
Regulatory Requirements ,
SFDR ,
Sustainable Finance ,
UK
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
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
5/24/2024
/ Climate Change ,
Cross-Border ,
Disclosure Requirements ,
EU ,
False Claims Act (FCA) ,
Fund Managers ,
Investment Funds ,
Private Funds ,
Private Investment Funds ,
Regulatory Standards ,
Reporting Requirements ,
SFDR ,
Sustainability ,
Sustainable Business Practices ,
Sustainable Finance ,
Transitional Arrangements ,
UK
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
At a first glance, it has to be recalled that in accordance with the Circular n° 781 dated 30 September 2016, the Luxembourg VAT authorities consider that the activity of a board member has an economic nature in relation to...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
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 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 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
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
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)