Overview of corporate tax work
Luxembourg continues to be a global leader as a platform for
international business, investment funds and cross-border
financing. The importance of economic substance and business
purpose for Luxembourg structures remains a particular focal point.
Notably, in December 2021, the European Commission ("EC")
published its proposed directive aimed at curbing the perceived
abusive use of so-called "shell" companies with a focus
on minimum substance requirements to avoid adverse tax implications
such as refusal of EU Directive or double tax treaty benefits.
Transfer pricing requirements continue to expand along with
increased enforcement activities by the Luxembourg tax authorities.
Accordingly, transfer pricing has become a central focus of risk
management for multinational groups with Luxembourg-based
cross-border financing and Alternative Investment Funds
("AIFs") utilising Luxembourg special-purpose vehicles
for downstream investments.
