On 19 December 2019, the Luxembourg Parliament voted both the
2020 Budget law, which terminates all pre-2015 tax rulings as of
the end of tax year 2019, and the law implementing the second EU
anti-tax avoidance directive (ATAD 2). Both laws will enter into
force once published in the Official Journal, and enter into effect
on 1 January 2020.
Termination of pre-2015 rulings in the 2020 Budget law
With respect to the 2020 Budget law, as previously explained in
our tax flash on Luxembourg Budget 2020, pre-2015
tax rulings will no longer be binding after the end of the tax year
2019. For companies with a tax year diverging from the calendar
year, the ruling is no longer binding already for their current tax
year. Taxpayers may request a new ruling (valid for five years)
under the procedure in place since 1 January 2015.
