ARTICLE · 16 JULY 2014

Amendment Of The EU Parent-Subsidiary Directive

BSP

Contributor

BSP

BSP

BSP is an independent full-service law firm based in Luxembourg. We are committed to providing the...

View firm profile

Explore more from BSP

On June 20th 2014, the Council of the European Union has agreed to an amendment to the the EU Parent-Subsidiary Directive 2011/96/EU.

European UnionTax

Bonn Steichen & Partners

On June 20^th 2014, the Council of the European Union has agreed to an amendment to the the EU Parent-Subsidiary Directive 2011/96/EU (the "Directive"), as proposed by the European Commission on November 25^th 2013.

As outlined in our newsletter dated January 2014, the proposed amendments focus on closing a loophole deriving from the use of hybrid loan arrangements. The objective of the new rules is to prevent cross-border companies from planning their intra-group payments in such a manner as to benefit from the provisions of the Directive in order to enjoy double non-taxation. In the future, the benefit of the tax exemption to income from a participation in an EU subsidiary will be denied if such income is deductible in the jurisdiction of the subsidiary.

We operate a free-to-view policy, asking only that you register in order to read all of our content. Please login or register to view the rest of this article.

Register for freeORLog in

Related Articles

Luxembourg Budget 2027: Lower Corporate Tax Rates And Key Changes For Businesses And Investors

The EU Updates Its List Of Non-Cooperative Tax Jurisdictions: Two Jurisdictions Removed

Atoz Tax Advisers

Luxembourg’s 2027 Budget Bill Proposes Corporate Tax Cuts And Changes To Capital Gains And Loss Carryforwards

Goodwin Procter LLP

Luxembourg Draft Budget 2027: Key Tax Measures For Businesses, Investors And Employers

Atoz Tax Advisers

Luxembourg Budget 2027– Proposed Tax Measures

Legal Intelligence Newsletters: sign up for the latest legal and regulatory news on your chosen topics

Read more about

Tax
- Corporate Tax

Related Comparative Guides

Comparative Guide

Tax Disputes

Comparative Guide

Tax

See more popular content from

TaxBSP

EU Tax Omnibus Package: Key Changes For Europe And Luxembourg

The European Commission's Omnibus proposal seeks to fundamentally reshape the EU's direct taxation framework by removing shareholding thresholds for dividend exemptions, eliminating prior authorization procedures, and harmonizing interest limitation rules across member states. This comprehensive reform promises to streamline cross-border investment structures while raising critical questions about the treatment of alternative investment funds and pension institutions under the new regime.

Luxembourg Budget 2027: Key Tax Measures

On 7 October 2026, the Luxembourg Government filed bill of law No. 8800 concerning the State budget for 2027 (the “Bill”) with the Chamber of Deputies. Alongside the budget itself, the Bill introduces a package of tax measures designed to increase Luxembourg’s tax competitiveness and support businesses, most of which would apply from tax year 2027.

VAT Liability Of Online Platforms

The CJEU confirmed the lawfulness of the liability of online platforms to collect VAT on total amounts due on electronic services in the recent Fenix case (C-695/20, 28 February 2023).

Arendt & Medernach

Luxembourg’s 2027 Budget Bill Proposes Corporate Tax Cuts And Changes To Capital Gains And Loss Carryforwards

Luxembourg's proposed 2027 budget law introduces significant corporate tax reforms, including a 1% reduction in corporate income tax rates that would lower the maximum aggregate tax burden in Luxembourg City to 22.80%. The Bill also extends the holding period for speculative gains on movable assets from six to twelve months and eliminates the 17-year limit on tax loss carryforwards, measures designed to enhance Luxembourg's competitiveness while encouraging longer-term investment strategies.

Goodwin Procter LLP

ECOFIN Council Reaches An Agreement On DAC8

At yesterday's ECOFIN meeting, the EU Council agreed on a general approach regarding foreseen amendments to the directive on administrative cooperation in the area of taxation.

Atoz Tax Advisers

2026 Luxembourg Budget Announced | Tax Measures To Come

On 8 October 2025, the Luxembourg Minister of Finance presented the 2026 budget (the "Budget Law") oriented towards growth and social cohesion.

Luxembourg Budget 2027: Key Tax Measures For Businesses

Luxembourg's Finance Minister has unveiled a draft budget for 2027 that includes significant tax reforms affecting businesses and investors. The proposed changes include a reduction in corporate income tax rates, the removal of time limits on loss carryforwards, and enhanced investment tax credits for digitalisation and green projects. However, the extension of the speculation period for capital gains from six to twelve months will require careful consideration by fund managers and investors planning asset

Form Over Substance: Why The Luxembourg Tribunal's Share Premium Ruling Cannot Stand

The Administrative Court of Luxembourg has issued significant rulings on the qualification of interest-free loans and the use of corporate tax losses in relation to abuse of law concepts. These decisions provide crucial clarity for corporate tax planning and compliance strategies in Luxembourg.

Atoz Tax Advisers

EU Commission Closes State Aid Investigations Into Amazon, Starbucks And Fiat Tax Rulings

Today, the European Commission has closed three in-depth State aid investigations into transfer pricing tax rulings granted by Luxembourg to Fiat and Amazon...

European UnionTax

ELVINGER HOSS PRUSSEN, société anonyme

ATOZ Insights - May 2025

As spring is upon us, the time has come to present our latest edition of our Insights, highlighting recent developments from the Grand Duchy, at European level, and in the Middle East over the past few months.

Atoz Tax Advisers

2026 Luxembourg Budget Announced | Tax Measures To Come

On 8 October 2025, the Luxembourg Minister of Finance presented the 2026 budget (the "Budget Law") oriented towards growth and social cohesion.

Transposition Of The Mobility Directive | A Review

The entry into force, on 2 March 2025, of the law of 17 February 2025 transposing in the Grand Duchy of Luxembourg Directive (EU) 2019/2121 of the European Parliament and the Council of 27 November 2019 on cross-border conversions, mergers and divisions entails important changes in the Luxembourg legal system...

LuxembourgCorporate/Commercial Law

Au Luxembourg, Qui Peut Pratiquer Le Conseil Juridique?

Le métier d’avocat fait partie de ces professions règlementées qui jouissent d’un monopole d’exercice.

LuxembourgLaw Practice Management

Real Estate Rich Companies Clause - Tax Treaty With France

Luxembourg signed a protocol to the income tax treaty with France on September 5th 2014 ("French Protocol").

Fourth AML Directive

The European Parliament vote on the final text of the fourth AML Directive is imminent. The draft Fourth AMLD is based on the revised FATF recommendations (February 2012), but goes beyond.

European UnionFinance and Banking

New CSSF Publications In Respect Of The AIFMD

The Luxembourg supervisory authority, the Commission de Surveillance du Secteur Financier, issued a template application questionnaire for Luxembourg alternative investment fund managers who may already wish to obtain approval by the CSSF as an AIFM.

LuxembourgFinance and Banking

《中国》杂志 | China Magazine

Relations between China and Luxembourg are older than a century. The relationship has evolved and adapted to the general context, emphasizing individual strengths and reflecting new developments.

ChinaInternational Law

EU Startup And Scaleup Strategy | "Choose Europe To Start And Scale"

On 28 May 2025, the European Commission adopted its EU Startup and Scaleup Strategy (the "Strategy") - a coordinated EU-level framework designed to support the creation, growth and internationalisation of innovative startups and scaleups.

LuxembourgFinance and Banking

A New Regime For European Venture Capital Funds

The regulation on European venture capital funds was published in the Official Journal of the European Union on April 17th 2013.

LuxembourgCorporate/Commercial Law

CSSF Circular 14/591 – Material Changes To UCIs

On July 22nd, the CSSF issued Circular 14/591 on protection of investors in case of a material change to an open-ended undertaking for collective investment.

LuxembourgFinance and Banking