As 2024 nears its end, it is time for our annual tax update. This update focuses on the tax trends and developments we foresee for 2025 and includes tips and takeaways.

Business restructurings are normally associated with a transfer of functions, risks, or assets between the entities of a group—and that means transfer pricing consequences.

On 24 July 2025, Draft Law No 8590 was submitted to the Luxembourg Parliament (Chambre des Députés) intending to update and render more attractive the tax regime for carried interest granted to managers of alternative investment funds.

Today, the EU Council updated the EU list of non-cooperative tax jurisdictions.

Last year, a Flemish TV show did a great spoof on Luxembourg, titled What if everybody forgot about Luxembourg? (see below with subtitles).

Recently, an Advocate General's opinion (the "Opinion") on Finnish CJEU case C-342/20 (the "Case") has been published.

On 12 May 2021, the General Court of the EU upheld the European Commission decision of June 2018 finding that Luxembourg had granted unlawful State aid to ENGIE by means of various tax rulings.

On 1 December 2020, the Luxembourg tax authorities issued Circular L.I.R. n°147/2, 166/2 and Eval. N°63 ("Circular") related to the application of the EU Parent Subsidiary Directive ("PSD") to...

Fully developed infrastructure of financial services and support functions...

In a decision of the German Federal Tax Court (GFTC) from 13 June 2018 (Decision I R 94/15 published on 17 October 2018), the GFTC ruled, among other things, that the German rules ...

In order to take into account the impact of homeworking due to the Covid-19 pandemic, Luxembourg signed an amicable tax agreement with Belgium on 19 May 2020 regarding the taxation of Luxembourg cross-border workers.

In January 2025, Luxembourg recently modified the impatriate tax regime. Its main objective is to attract qualified foreign profiles.

Please find hereafter a high-level summary of some tax aspects of debt financing at the level of a Luxembourg holding company.

We have already enjoyed early spring days, so it is time for our first 2022 ATOZ Insights.

On 31 October 2024, the Luxembourg government published amendments to bill of law 8396 in order to incorporate the OECD's Pillar 2 Administrative Guidance issued in June 2024 into domestic law.

2021 is already coming to an end and 2022 is just around the corner. Some major events have certainly stamped 2021, such as the continued existence of COVID-19, COP26 and, in the tax world, agreement on Pillars One and Two.

On 14 October 2020, the Luxembourg government published the 2021 budget bill of law (the Bill).

On 30 March 2020, the Luxembourg government issued a draft law (the "Draft Law"), which should be applicable as of 1 January 2021, introducing new rules on the limitation of the deduction of...

Luxembourg securitisation vehicles with main income sources other than interest income like capital gains or non-performing loans may not effectively use their tax neutrality.

On 22 August 2025, the Luxembourg tax authorities published a second circular on the application of the reverse hybrid rules (LIR 168quater/2).