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  • Article

    VAT Deduction Right Of Holding Companies: Important Judgement Of The Court Of Cassation

    The Luxembourg Court of Cassation (hereafter the "Court") ruled that the VAT deduction right of a holding company does not have to be limited by the 1:1 ratio when it can be demonstrated
    LuxembourgTax
    Atoz Tax Advisers
    Atoz Tax Advisers
  • Article

    The UK Tax Reform: Taxing Gains Realised By Non-Residents On UK Immovable Property

    It should be noted that the government has not yet determined how the existing regime that taxes gains on enveloped dwellings will be harmonised with the new rules.
    United KingdomTax
    Atoz Tax Advisers
    Atoz Tax Advisers
  • Article

    ESMA's Opinions To Support European Supervisory Convergence In The Brexit Context

    Most of the principles invoked by ESMA in its recent opinions on the supervisory convergence in the Brexit context are a reinstatement of rules and guidelines already provided for by the relevant European legislation.
    European UnionGovernment, Public Sector
    Atoz Tax Advisers
    Atoz Tax Advisers
  • Article

    2024 Tax Measures Boosting The Construction Sector Extended Until 30 June 2025

    Yesterday, the Luxembourg parliament passed a law extending the temporary tax measures introduced by the law dated 22 May 2024 introducing various measures to revive the housing market...
    LuxembourgReal Estate and Construction
    Atoz Tax Advisers
    Atoz Tax Advisers
  • Article

    Investment Tax Credit Regime To Be Modernised As From 2024

    On 13 July 2023, a draft law was presented to Parliament which introduces a major reform of the current investment tax credit framework, with effect as from tax year 2024.
    LuxembourgTax
    Atoz Tax Advisers
    Atoz Tax Advisers
  • Article

    Luxembourg Further Improves The Flexibility And Attractiveness Of Its Securitisation Law

    The law dated 22 March 2004 on securitisation has created a very successful and reliable framework for enabling a large panel of securitisation, financing, and repackaging transactions.
    LuxembourgTax
    Atoz Tax Advisers
    Atoz Tax Advisers
  • Article

    Nouvelle circulaire en matière de Prix de Transfert | Le nouveau régime luxembourgeois applicable aux sociétés de financement

    Le 27 décembre 2016, l'administration des contributions directes («l'ACD ») a émis une nouvelle circulaire sur le traitement fiscal des sociétés réalisant des activités de financement intra-groupe (la « Circulaire »).
    LuxembourgTax
    Atoz Tax Advisers
    Atoz Tax Advisers
  • Article

    Upcoming Amendments To The Luxembourg Procedure In Tax Matters

    On 28 March 2023, a new draft law (the "Draft Law") was presented to the Parliament which amends the Luxembourg General Tax Law ("GTL") as well as some other laws...
    LuxembourgTax
    Atoz Tax Advisers
    Atoz Tax Advisers
  • Article

    European Commission Releases FASTER Directive Proposal

    On 19 June 2023, the European Commission published the Proposal for a Council Directive on Faster and Safer Relief of Excess Withholding Taxes (hereafter "FASTER" or "the Proposal").
    European UnionTax
    Atoz Tax Advisers
    Atoz Tax Advisers
  • Article

    Refunds Of WHT – European Court Decision On Discrimination Of Luxembourg Specialised Investment Fund

    A few weeks ago, an important decision was issued by the Court of Justice of the European Union (the "Court") striking down a German law according to which a Specialised Investment Fund...
    European UnionTax
    Atoz Tax Advisers
    Atoz Tax Advisers
  • Article

    VAT Deduction Right Of Lux PropCos Owning/exploiting German Real Estate – VAT Changes

    In its decision C-931/19 ("Titanium case"), the Court of Justice of the European Union ("CJEU") ruled that a foreign company should not be considered as having a fixed establishment...
    GlobalTax
    Atoz Tax Advisers
    Atoz Tax Advisers
  • Article

    Law Implementing ATAD Enters Into Force

    The law of 21 December 2018 implements the EU Anti-Tax Avoidance Directive ("ATAD"), the aim of ATAD being to implement the BEPS (Base Erosion and Profit Shifting) ...
    LuxembourgFinance and Banking
    Atoz Tax Advisers
    Atoz Tax Advisers
  • Article

    2018 Budget: Main Tax Measures

    On 11 October 2017, Finance Minister Gramegna presented the 2018 budget to the Parliament.
    LuxembourgTax
    Atoz Tax Advisers
    Atoz Tax Advisers
  • Article

    Luxembourg Committed To Revitalising The Construction Sector And The Property Market With Tax Measures

    On 19 December, the Luxembourg Parliament passed the 2025 budget law (bill n°8444) at first reading. From a tax perspective, the 2025 budget law mainly introduces new temporary tax measures, applicable until 30 June 2025...
    LuxembourgTax
    Atoz Tax Advisers
    Atoz Tax Advisers
  • Article

    Luxembourg Tribunal Classified An Interest-free Loan As A (Hidden) Capital Contribution: What Went Wrong?

    On 23 September 2022, the Luxembourg Administrative Tribunal (Tribunal Administratif, the "Tribunal", which is the first instance jurisdiction) held its decision (the "Decision")...
    LuxembourgTax
    Atoz Tax Advisers
    Atoz Tax Advisers
  • Article

    Luxembourg Warrant Plan Regime Amended

    On 29 November 2017, the Luxembourg tax authorities released the highly anticipated circular on stock option/warrant plans
    LuxembourgTax
    Atoz Tax Advisers
    Atoz Tax Advisers
  • Article

    New Measure Denying The Tax Deduction Of Interest And Royalties To Entities In Blacklisted Jurisdictions

    On 30 March 2020, a draft law amending the Luxembourg corporate income tax law so as to deny, in Luxembourg, the deduction of interest and royalty expenses directed to entities in...
    LuxembourgTax
    Atoz Tax Advisers
    Atoz Tax Advisers
  • Article

    Political Agreement Reached On EU Proposal Setting New Transparency Rules For Intermediaries

    Therefore, in order to be taken into account, they must fulfil a main benefit test.
    LuxembourgTax
    Atoz Tax Advisers
    Atoz Tax Advisers
  • Article

    VAT In The Digital Age: The European Commission's Latest Proposal

    On 8 December 2022, the European Commission presented the legislative package ViDa , 1 aiming to (i) modernise businesses' VAT reporting obligations, (ii) address the challenges...
    LuxembourgTax
    Atoz Tax Advisers
    Atoz Tax Advisers
  • Article

    Qatar Introduces A Minimum Top Up Tax In Accordance With The OECD's Pillar Two Rules

    On 27 March 2025, the Qatari Ministry of Justice published a new Law No. (22) of 2024, amending certain provisions of the Income Tax Law issued by Law No. (24) of 2018 (the "Law").
    QatarTax
    Atoz Tax Advisers
    Atoz Tax Advisers

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