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Some may be under the impression that substance is a widely known tax concept and that there is not much to say.

One of the many burdens for the financial industry, in terms of processes, is the responsibility of collating tax information and communicating it to the tax authorities.

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.

Whilst some countries have had comprehensive rules on controlled foreign corporations for years, Luxembourg only introduced such rules recently, further to the implementation of a European directive.

As a global mobility tax advisor I often hear comments like I am not taxable in country A as long as I stay for fewer than 183 days. Another common one is I am being paid from Country A, so I am not taxable in Country B.

Globally, the credit fund industry has experienced a notable surge in the last decade. The size of the market was around USD 250 billion at the end of 2010 and while it was approximately USD 1.4 trillion at the start of 2023.

On 30 June 2023, the Luxembourg tax authorities (LTA) released an update to their FAQ regarding DAC 6 (the Updated FAQ).

On 21 March 2018, the EU Commission presented two Proposals for Council Directives specifically targeting the digital economy.

On 17 July 2023, the OECD / BEPS Inclusive Framework (IF) released new documents in relation to its Two-Pillar solution.

es conventions fiscales bilatérales signées entre le Grand-Duché du Luxembourg et les pays voisins définissent des seuils concernant les jours de travail réalisés à partir des pays de résidence des salariés non-résidents.

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

On 7 June 2017, Luxembourg together with 67 other jurisdictions, signed the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS ("Multilateral Instrument" or "MLI").

On 7 June 2017, Luxembourg together with 67 other jurisdictions, signed the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS ("Multilateral Instrument" or "MLI").

On 9 April 2019, Luxembourg deposited with the Organisation for Economic Cooperation and Development ("OECD") its instrument of ratification of the Multilateral Instrument ...

On 7 June 2017, Luxembourg together with 67 other jurisdictions, signed the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS ("Multilateral Instrument" or "MLI").

Another perspective to the steady expansion of Luxembourg tax treaties must be added. Luxembourg endorsed on 13 March 2009 the international standard of exchange of information upon request embodied in article 26-5 of the OECD model tax convention.

More than ever, it's on everyone's mind, especially in the context of the OECD's Base Erosion and Profit Shifting (BEPS) action and the Multilateral Instrument (MLI).