ARTICLE · 10 JUNE 2019

Tax Dispute Resolution Mechanism

ELVINGER HOSS PRUSSEN, société anonyme

Explore more from ELVINGER HOSS PRUSSEN, société anonyme

The Bill of Law 7431 ("Bill") introduced by the Luxembourg government on 11 April 2019 implements the European Union ("EU") Directive 2017/1852 dated 17 October 2017 on tax dispute resolution mechanisms in the EU.

LuxembourgTax

Elvinger Hoss Prussen

The Bill of Law 7431 ("Bill") introduced by the Luxembourg government on 11 April 2019 implements the European Union ("EU") Directive 2017/1852 dated 17 October 2017 on tax dispute resolution mechanisms in the EU (the "Directive"). The Directive meets the BEPS Action Plan 14 minimum standards and is a subsidiary to the mandatory binding arbitration clause of the Multilateral Instrument¹ (if applicable). The objective of the Directive is to provide an efficient resolution mechanism for disputes arising between EU Member States regarding the interpretation and application of agreements and conventions that provide for the elimination of double taxation of income and, where applicable, capital ("Resolution Mechanism")

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

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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

Related Comparative Guides

Comparative Guide

Tax

Comparative Guide

Tax Disputes

See more popular content from

Tax

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’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

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

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