152 results found

On 7 June 2022, Luxembourg and the UK signed a new double tax treaty (the "DTT") and an additional Protocol which will replace the double tax treaty signed back in 1967 (the "old tax treaty").

The New Treaty contains significant amendments, not all of which are in line with the 2017 OECD Model Tax Convention.

This Back to Basics note follows our key concepts briefings, which intend to provide high-level insights regarding funds fundamentals, funds vehicles and operational considerations, available here.

On 9 June 2023, the Luxembourg tax authorities ("LTA") released a circular (the "Circular") on the reverse hybrid rule, as introduced as from tax year 2022 by Article 168quater of the Luxembourg...

Le Tribunal administratif de Paris valide la remise en cause par l'administration fiscale du taux réduit de retenue à la source de 5 % prévu par la convention franco-luxembourgeoise en présence de dividendes versés...

Several tax measures have been introduced, potentially impacting taxpayers with operations in Luxembourg. The following newsflash summarises the most important developments.

2023 was another year rich in tax controversy, with more than 160 judgments issued in direct tax litigation cases. Whilst this is less than in 2022, several high-profile cases attracted...

On 2 April 2020, the Court of Justice of the European Union ("CJEU") rendered a decision ("Decision") in case C-458/18, ("GVC Services") in response to a request for a preliminary ruling...

This Back to Basics note follows our key concepts briefings, which intend to provide high-level insights regarding funds fundamentals, funds vehicles and operational considerations, available here.

On 23 May 2024, bill of law 8388 (Bill) was submitted to the Luxembourg Parliament, introducing several measures that complement existing domestic tax rules...

An Amendment to the Convention of 28 June 1993 between the Grand Duchy of Luxembourg and the Russian Federation regarding the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to ...

On 8 August 2019, the Luxembourg Government submitted a draft law to the Parliament (the Draft Law) to implement the Council Directive (EU)

Instead, the general principle of substance over form applies to determine the tax classification of an instrument as debt or equity, requiring an economic and financial analysis of each transaction.

On 15 December 2022, the EU Member States finally reached an agreement concerning the Directive on ensuring a global minimum level of taxation for multinational and large-scale domestic groups in the Union...

The new edition of the EU Tax Alert is available. With this publication we would like to keep you informed about the latest developments on EU tax law. We have summarized the highlights of this edition below.

Domestic tax controversy, encompassing both (i) objections against assessments or hierarchical appeals against other individual decisions and (ii) subsequent appeals...

After a very intense debate, the law on the 2017 tax reform (the "Law") was adopted on 14 December 2016 by a rather slim majority of the Luxembourg Parliament. Subsequently, on 23 December 2016...