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  • Article

    Updated Circular On Share Exchange Transactions

    On 27 July 2021, the tax authorities published updated guidelines on Article 22bis of the Luxembourg income tax law which sets out share exchange scenarios that may benefit from a tax deferral...
    LuxembourgTax
    ELVINGER HOSS PRUSSEN, société anonyme
    ELVINGER HOSS PRUSSEN, société anonyme
  • Article

    DEBRA Directive

    On 11 May 2022, the European Commission published the proposal for the so-called "DEBRA".
    European UnionTax
    ELVINGER HOSS PRUSSEN, société anonyme
    ELVINGER HOSS PRUSSEN, société anonyme
  • Article

    SCS and SCSp: Income Direct Tax Treatment

    The administrative Circular LIR n°14/4 of 9 January 2015 recalls that SCS (Société en commandite simple) and SCSp (Société en commandite spéciale) are transparent for corporate income tax purposes.
    LuxembourgTax
    Wildgen
    Wildgen
  • Article

    Free Movement Of Capital Upheld: ECJ Ruling Condemns German Tax Treatment Of Luxembourg Specialised Investment Funds

    In the case at hand, a Luxembourg fund governed by the "Specialized Investment Fund" regime held directly properties in Germany, received rental income therefrom and became liable to corporate tax in Germany according to German law ...
    LuxembourgTax
    Chevalier & Sciales
    Chevalier & Sciales
  • Video

    Fund Distribution To German Investors In 2018 – What Will Change? #TAX - Video

    A focus on the new German tax rules applying to Luxembourg investment funds in relation to their German investors and German investments and illustrate the impacts under the German Investment Tax Reform 2018.
    LuxembourgTax
    Arendt & Medernach
    Arendt & Medernach
  • Article

    Luxembourg Holdings: V The Minimum Taxation And The Taxation On The Net Wealth (Video)

    It is often reported that the only disadvantages of the Soparfi Luxembourg holding is the obligation to pay a Wealth Tax and a minimum taxation every year.
    LuxembourgTax
    Hance Law Avocats
    Hance Law Avocats
  • Article

    New Circulars Summary: January And February 2018

    This tax circular publishes the official year-end and average forex conversion rates for Luxembourg tax purposes in 2017 for the use of a non-EUR functional currency for tax purposes.
    LuxembourgTax
    ELVINGER HOSS PRUSSEN, société anonyme
    ELVINGER HOSS PRUSSEN, société anonyme
  • Article

    Taxation Of Belgian Commuters

    The remuneration is not borne by a permanent establishment which the employer has in the State of employment.
    LuxembourgTax
    BSP
    BSP
  • Article

    Pillar Two: Jan. 2025 OECD Guidance (Part 1) – New York Office Snippet

    Loyens & Loeff New York regularly posts ‘Snippets' on a range of EU tax and legal topics.
    European UnionTax
    Loyens & Loeff
    Loyens & Loeff
  • Article

    Carry Forward Losses And Advance Tax Clearance Regarding A Financing Activity

    A company is not permitted to carry forward losses accrued during the years covered by a prior advance tax clearance.
    LuxembourgFinance and Banking
    Chevalier & Sciales
    Chevalier & Sciales
  • Article

    Bill Of Law On Exit Tax

    The Luxembourg Government has recently submitted to Parliament bill of law n°6556, which aims to amend some of the Luxembourg provisions regarding enterprise migration considered as not to be compliant with EU law.
    LuxembourgTax
    Wildgen
    Wildgen
  • Article

    EU Tax Law Highlights Of 2019

    In the course of 2019 there were several developments in EU tax law. This annual edition of EU Tax Alert provides an overview of those developments.
    LuxembourgTax
    Loyens & Loeff
    Loyens & Loeff
  • Article

    Law Implementing Public Country-By-Country Reporting Directive Adopted By The Luxembourg Parliament

    Luxembourg, like all EU Member States, had until 22 June 2023 to transpose the so-called public country-bycountry reporting ("CbCR") Directive into national law.
    LuxembourgTax
    Atoz Tax Advisers
    Atoz Tax Advisers
  • Article

    Real Estate Rich Companies Clause - Tax Treaty With France

    Luxembourg signed a protocol to the income tax treaty with France on September 5th 2014 ("French Protocol").
    LuxembourgTax
    BSP
    BSP
  • Article

    Luxembourg Council Of State Opinion On The Private Foundation Bill

    The Luxembourg Council of State has issued its opinion dated 29 April 2014 on the bill of law to introduce in Luxembourg the private foundation.
    LuxembourgCorporate/Commercial Law
    Wildgen
    Wildgen
  • Article

    Bill Implementing The EU Public CbC Reporting

    The Bill 8158 transposing EU Directive 2021/2101 amending Directive 2013/34/EU as regards disclosure of income tax information by certain undertakings...
    European UnionTax
    ELVINGER HOSS PRUSSEN, société anonyme
    ELVINGER HOSS PRUSSEN, société anonyme
  • Article

    Bill Of Law Implementing The EU Public CbC Reporting

    The draft law 8158 transposing EU Directive 2021/2101 amending Directive 2013/34/EU as regards disclosure of income tax information by certain undertakings and branches ("EU public country-by-country ("CbC")...
    European UnionTax
    ELVINGER HOSS PRUSSEN, société anonyme
    ELVINGER HOSS PRUSSEN, société anonyme
  • Article

    Comparison Table Of Luxembourg Investment Vehicles – Update July 2022

    Our comparison table of Luxembourg investment vehicles has been updated. It takes into account the changes to the securitisation law adopted by the law of 25 February 2022.
    LuxembourgFinance and Banking
    Chevalier & Sciales
    Chevalier & Sciales
  • Article

    Luxembourg 2026 Budget Bill – Tax Stability

    The Luxembourg government has submitted its 2026 budget bill to Parliament, reaffirming its commitment to fiscal stability and international competitiveness.
    LuxembourgTax
    Loyens & Loeff
    Loyens & Loeff
  • Article

    Luxembourg ATAD I Implementation Creates Uncertainty In Capital Market Transactions

    Voted into Luxembourg law on 18 December 2018, the Anti-Tax Avoidance Directive I (ATAD I) now applies, with its provisions applicable as from fiscal years starting on or after 1 January 2019,
    LuxembourgTax
    Intertrust
    Intertrust

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