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10th Annual International Tax Developments Seminar - A Recap
During our 10th Annual International Tax Developments Seminar, several of our tax experts discussed the latest international tax developments.
Loyens & Loeff
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ATAD 3 / Unshell Directive Proposal Officially Dropped!
After being stalled at the draft stage for over three years, it results from the ECOFIN report 9960/25 of 18 June 2025...ELVINGER HOSS PRUSSEN, société anonyme - Article
Bill N°7746 Regarding Amendments To Certain Tax, Financial And Budgetary Deadlines In The Context Of The State Of Emergency
Bill n°7746 regarding amendments to certain tax, financial and budgetary deadlines in the context of the state of emergency was introduced on 15 January by Mr Gramegna, Finance Minister ("Bill")...Wildgen - Article
Budget 2023 - Tax Measures
On 12 October 2022, the 2023 budget draft law was presented to Parliament. As expected during this period of crisis and uncertainty, only some targeted tax measures will be introduced as from 2023.
Atoz Tax Advisers - Article
COVID-19: Income Tax And Social Security Measures For Cross-Border Workers
The protocols to the double tax treaties concluded by Luxembourg with Belgium, France and Germany provide rules allowing cross-border workers to perform their activities outside of their employment state...Atoz Tax Advisers - Article
Director's Fees: 2018 Tax Year Still Open For VAT Refund
Following the Court of Justice of the European Union (CJEU)'s ruling of 21 December 2023 in case C-288/22, the Luxembourg VAT authorities published on 15 January 2024 a newsletter...ELVINGER HOSS PRUSSEN, société anonyme - Article
French Cross-Border Workers Will Be Allowed 34 Teleworking Days Per Year From 1 January 2023
On 7 November 2022, the French and Luxembourg governments signed an amendment to paragraph 3 of the protocol to the existing treaty between the two countries for the avoidance of double taxation...Arendt & Medernach - Article
Group Restructuring – Abuse Of Law: Luxembourg Administrative Tribunal Of 15 May 2023, N° 46.042
In 2011, a Luxembourg company (Company A) granted a profit participating loan (Loan) to its Belgian subsidiary (Company B), which held debt securities issued by another entity (the Securities).Chevalier & Sciales - Article
Guidance On The Prime Participative Regime For Companies Forming A Fiscal Unity
The profit sharing bonus ("prime participative") has been introduced by the Luxembourg 2021 Budget Law of 19 December 2020 in order to keep Luxembourg attractive for talents. In this respect...ELVINGER HOSS PRUSSEN, société anonyme - Article
Luxembourg's New Carried Interest Tax Regime Is In Force
As expected, the law implementing the new Luxembourg carried interest tax regime has been passed and is applicable as from 2026...Herbert Smith Freehills Kramer LLP - Article
Luxembourg Council Of State Greenlights Carried Interest Draft Law
Today, the Luxembourg Council of State issued its second opinion on the carried interest draft law (the "Draft Law")...Atoz Tax Advisers - Article
Luxembourg Directors And VAT: Adjusting To The ECJ's 2023 Ruling
The European Court of Justice, rendered on 21 December 2023, a decision regarding the classification of directors' activities within the framework of Luxembourg VAT law.Chevalier & Sciales - Article
Luxembourg Tax Authorities Issue First FAQ Regarding Pillar Two
On 25 March 2024, the Luxembourg tax authorities released guidance in the form of FAQ on the recognition of pre-regime deferred tax assets and liabilities under the Luxembourg Pillar Two rules.Loyens & Loeff - Article
Luxembourg VAT Authorities Issue New Circular On Company Cars
The new administrative circular 807bis dated 28 April 2023 ("Circular 807bis") complements and clarifies the administrative circular 807 dated 11 February 2021 on company cars ("Circular 807").ELVINGER HOSS PRUSSEN, société anonyme - Article
Measures On Telework For Cross-border Workers
As part of an agreement concluded with France on 1 October 2022 to permanently increase to 34 the total number of days of teleworking allowed to French frontier workers...ELVINGER HOSS PRUSSEN, société anonyme - Article
New Tax Measures Adopted By The Luxembourg Parliament
On 11 December 2024, the Luxembourg Parliament discussed and passed three draft laws that include tax provisions, modifying and clarifying existing tax rules...Atoz Tax Advisers - Article
Strengthened Cooperation Between Luxembourg Tax Agencies
The ACD and the AEDT have signed a memorandum containing instructions for implementing the amended law of 19 December 2008 on inter-administrative and judicial cooperation...Arendt & Medernach - Article
Tax Administrative Guidelines On The Equity Escape Clause
The Luxembourg Tax Authorities updated twice the circular of 8 January 2021 dealing with certain aspects of the interest deduction limitation rule ("IDLR")...ELVINGER HOSS PRUSSEN, société anonyme - Article
The Use Of Corporate Tax Losses And The Concept Of Abuse Of Law: The Administrative Court Restores Much Needed Legal Certainty
On 30 March 2023, the Luxembourg Administrative Tribunal (Tribunal Administratif, the "Tribunal", which is the first instance jurisdiction) held its decision in a case that concerns the use of corporate tax losses by a Luxembourg company ("LuxCo").Atoz Tax Advisers - Article
US Fund Managers: What To Know About Luxembourg Payroll & Social Security Taxes – New York Office Snippet
Setting up an office in Luxembourg offers strategic advantages for US fund managers to access EU capital markets.Loyens & Loeff