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  • 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")...
    LuxembourgTax
    ELVINGER HOSS PRUSSEN, société anonyme
    ELVINGER HOSS PRUSSEN, société anonyme
  • Article

    Tax Reform 2017

    The Luxembourg draft law N° 7020 submitted by the Luxembourg government to the Luxembourg Parliament on 26 July 2016 foresees the introduction of tax measures affecting both individual and corporate taxpayers.
    LuxembourgTax
    Deloitte Luxembourg
    Deloitte Luxembourg
  • Article

    Tax Reform: How To Respond To The Quest For Substance In A Post-BEPS World?

    In the current environment where fair and acceptable tax competitiveness have become essential, Luxembourg's government announced, at the end of February 2016, its proposed measures for the tax reform to be implemented in 2017.
    LuxembourgTax
    KPMG Luxembourg
    KPMG Luxembourg
  • Article

    The 2021 Draft Italian Budget Law

    The 2021 draft Italian budget law provides for new interesting tax measures applicable from 1st of January 2021 that will undoubtedly enhance investments in Italian companies by European investment
    LuxembourgTax
    Arendt & Medernach
    Arendt & Medernach
  • Article

    The BlackRock VAT Case: An Impossible Combination Of Artificial Intelligence And The VAT Exemption?

    BlackRock Investment Management (UK) Ltd ("BlackRock") was a company responsible for the management of funds.
    LuxembourgTax
    Arendt & Medernach
    Arendt & Medernach
  • 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").
    LuxembourgTax
    Atoz Tax Advisers
    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.
    LuxembourgTax
    Loyens & Loeff
    Loyens & Loeff
  • Article

    2020 Dutch Budget Adopted - Increased Substance Requirements For Dutch Resident Service Companies As From 2021

    On 17 December 2019, the Upper House of Parliament approved the 2020 Dutch Budget proposals (the Budget), the proposals implementing the amended EU Anti-Tax Avoidance Directive to
    LuxembourgCorporate/Commercial Law
    Loyens & Loeff
    Loyens & Loeff
  • Article

    Launching EU Investment Hubs: Private Funds – Repatriating Cash Out Of Luxembourg Acquisition Structures – New York Office Snippet

    LuxCo typically takes the form of Luxembourg private limited liability company (S.à r.l.), while the Fund typically takes the form of a limited partnership formed under the laws of the relevant jurisdiction.
    LuxembourgCorporate/Commercial Law
    Loyens & Loeff
    Loyens & Loeff
  • Article

    Special Limited Partnerships (SLPS) Introduced In Luxembourg

    The Luxembourg limited partnership regime is being modernised to become more attractive for private equity, venture capital and real estate transactions.
    LuxembourgCorporate/Commercial Law
    Wildgen
    Wildgen
  • Article

    Impact Of The 30%-ruling And Work-related Costs Scheme On The Definition Of Wages For The Purposes Of The Pseudo-final Levy On Excessive Severance Payments

    On 4 April 2025, the Dutch Supreme Court ruled that the 30%-reimbursement qualifies as wages for the purposes of the pseudo-final levy on excessive severance payments.
    LuxembourgEmployment and HR
    Loyens & Loeff
    Loyens & Loeff
  • Article

    ELTIF Snippet Series #2 US Fund Managers: Pairing The ELTIF's With A Luxembourg Fund Label And Selecting Its Legal Form

    The ELTIF is an EEA-wide fund label designed to attract capital from EU HNWIs. In Luxembourg, structuring an ELTIF involves combining three key layers...
    LuxembourgFinance and Banking
    Loyens & Loeff
    Loyens & Loeff
  • Article

    Luxembourg Circular N° 821 Introduces New Digital Forms For UCI, SIF, And RAIF Subscription Tax Filings

    On 15 July 2024, the Luxembourg indirect tax authorities issued Circular n° 821, introducing new digital forms for the submission of quarterly subscription tax returns.
    LuxembourgFinance and Banking
    Chevalier & Sciales
    Chevalier & Sciales
  • Article

    Luxembourg Confirms Debt Treatment Of Interest-Free Loan

    In a final judgment rendered on 23 November 2023, the administrative court confirmed that an interest-free loan in the case at hand qualified as debt instrument for tax purposes.
    LuxembourgFinance and Banking
    Loyens & Loeff
    Loyens & Loeff
  • Article

    CSSF Study On The AML/CFT Controls Applied In Terms Of Preventing Tax Offences

    Following the "UCI On-Site inspections", the CSSF concluded that the mitigation measures put in place regarding the tax offences were satisfactory.
    LuxembourgGovernment, Public Sector
    Chevalier & Sciales
    Chevalier & Sciales
  • Article

    Real Estate Investment In Luxembourg: The Framework And Tools For Long-Term Success

    In its latest report, the ALFI highlights the progress and consolidation of investments in the discreet area of ​​Real Estate Investment Funds (REIFS) and the figures speak for themselves:
    LuxembourgReal Estate and Construction
    Hance Law Avocats
    Hance Law Avocats
  • Article

    The European Commission Takes France To Court Over Tax Discrimination Against Foreign Pension And Investment Funds

    According to articles 119 bis and 187 of the French code général des impôts, the dividends paid to foreign pension and investment funds are subject to a withholding tax of 25% or 15% if there is a bilateral treaty between France and the State where the investor is established.
    LuxembourgStrategy
    Wildgen
    Wildgen
  • Article

    New Proposal To Amend EU Directive On Administrative Cooperation In The Field Of Taxation (DAC 8)

    The EU Commission has proposed an amendment_ of Council Directive 2011/16/EU on administrative cooperation in the field of taxation, known as DAC 8, that aims to increase transparency and accountability
    LuxembourgTechnology
    Arendt & Medernach
    Arendt & Medernach
  • Article

    G7 Global Minimum Tax Agreement With The US Announced - Relief For EU Funds And EU-owned MNEs As The US Intend To Drop Withholding Tax Threat

    Yesterday, ten days after the conclusion of the last G7 summit held in Canada, US Secretary of the Treasury Scott Bessent announced an international tax agreement reached at the G7.
    GlobalTax
    Atoz Tax Advisers
    Atoz Tax Advisers
  • Article

    Luxembourg Introduces New Stock Option Tax Rules And An Innovative Start-up Incentive Regime

    Luxembourg is introducing significant changes to its stock option taxation framework, establishing a new statutory regime while codifying treatment under ordinary rules.
    LuxembourgTax
    Atoz Tax Advisers
    Atoz Tax Advisers

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