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  • Article

    Luxembourg's New Start-Up Tax Credit: Key Features And Implications For Investors As From 2026

    Yesterday, the Luxembourg Parliament passed a law (the "Law") which introduces, as of the 2026 tax year, a new start-up tax credit (the "Start-Up Tax Credit")...
    LuxembourgTax
    Atoz Tax Advisers
    Atoz Tax Advisers
  • Article

    Luxembourg Signs New Double Tax Treaty With The UK

    On 7 June 2022, Luxembourg and the UK signed a new double tax treaty (the "DTT") and an additional Protocol which will replace the double tax treaty signed back in 1967 (the "old tax treaty").
    LuxembourgTax
    Atoz Tax Advisers
    Atoz Tax Advisers
  • Article

    UAE Public Clarification Released On The Application Of The Valuation Method Under The Transitional Rules For Real Estate Developers

    On 26 September 2025, the Ministry of Finances ("MoF") of the UAE issued a corporate tax public clarification (the "Public Clarification") on the application of the valuation...
    United Arab EmiratesTax
    Atoz Tax Advisers
    Atoz Tax Advisers
  • Article

    First Guidelines Released On The Luxembourg Reverse Hybrid Rule!

    On 9 June 2023, the Luxembourg tax authorities ("LTA") released a circular (the "Circular") on the reverse hybrid rule, as introduced as from tax year 2022 by Article 168quater of the Luxembourg...
    LuxembourgTax
    Atoz Tax Advisers
    Atoz Tax Advisers
  • Article

    Luxembourg And Germany Sign Amending Protocol To Their Tax Treaty

    On 6 July 2023, Luxembourg and Germany signed an amending protocol ("the Protocol") to the Germany - Luxembourg double tax treaty...
    LuxembourgTax
    Atoz Tax Advisers
    Atoz Tax Advisers
  • Article

    VAT & Cash-flow Optimisation: Practical Cash-flow Strategies For Luxembourg Businesses

    As usual, like at the beginning of each year, Luxembourg VAT taxable persons received VAT account statements from the Luxembourg Treasury.
    LuxembourgTax
    Atoz Tax Advisers
    Atoz Tax Advisers
  • Article

    The Modification Of A Vertical Tax Consolidation Group Into A Horizontal Tax Consolidation Group Does Not End The Tax Consolidation Regime

    On 14 May 2020, the Court of Justice of the European Union ("CJEU") ruled on the Luxembourg tax consolidation regime and took a very positive decision for the Luxembourg corporate...
    LuxembourgTax
    Atoz Tax Advisers
    Atoz Tax Advisers
  • Article

    Luxembourg Tax Authorities Release New Guidelines For Intra-Group Financing Activities

    On 27 December 2016, the Luxembourg tax authorities released a new circular (the Circular) on the tax treatment of intra-group financing activities.
    LuxembourgTax
    Atoz Tax Advisers
    Atoz Tax Advisers
  • Article

    ATOZ Insights - September 2017

    This year again, tax news did not take a summer holiday: in early August, the long awaited draft law introducing the new Luxembourg IP regime was released.
    LuxembourgTax
    Atoz Tax Advisers
    Atoz Tax Advisers
  • Article

    Pillar Two: The OECD Grants Luxembourg The Transitional Qualified Status And Releases New Guidance On Deferred Tax Assets And The GloBE Information Return

    On 15 January 2025, the OECD published the list of countries that have already implemented the Global Anti-Base Erosion (GloBE) Model Rules, also known as Pillar Two, introducing a global minimum level of taxation.
    LuxembourgTax
    Atoz Tax Advisers
    Atoz Tax Advisers
  • Article

    UAE E-Invoicing 2026: What Businesses Need To Know About The New Framework, Timeline And Key Compliance Obligations

    The United Arab Emirates has officially entered the era of mandatory e-invoicing. In late 2025, the Ministry of Finances ("MoF") issued Ministerial Decision No. 243 of 2025 establishing the new electronic invoicing system...
    United Arab EmiratesTax
    Atoz Tax Advisers
    Atoz Tax Advisers
  • Article

    Principes de l'OCDE en matière de prix de transfert | Nouvelles lignes directrices sur l'allocation des risques

    Les Principes de l'OCDE fournissent de nouvelles lignes directrices pour l'allocation des risques : cependant, le cadre de l'analyse des risques ajoute une couche de complexité à l'analyse des prix de transfert.
    LuxembourgTax
    Atoz Tax Advisers
    Atoz Tax Advisers
  • Article

    Non-Application Of The Parent Subsidiary Directive To Companies Incorporated In Gibraltar: Consequences For Luxembourg

    On 2 April 2020, the Court of Justice of the European Union ("CJEU") rendered a decision ("Decision") in case C-458/18, ("GVC Services") in response to a request for a preliminary ruling...
    European UnionTax
    Atoz Tax Advisers
    Atoz Tax Advisers
  • Article

    Les règles relatives aux sociétés étrangères contrôlées au Luxembourg

    La réforme fiscale 2019 transpose en droit fiscal luxembourgeois la directive établissant des règles pour lutter contre les pratiques d'évasion fiscale qui ont une incidence directe sur le fonctionnement du marché intérieur ...
    LuxembourgCorporate/Commercial Law
    Atoz Tax Advisers
    Atoz Tax Advisers
  • Article

    Luxembourg Launches The Implementation Of The Public CbC Directive

    On 24 February 2023, the draft law ("Draft Law") implementing the so-called "public country-by-country reporting Directive" (the "public CbCR Directive" or "the Directive") was presented to Parliament.
    European UnionTax
    Atoz Tax Advisers
    Atoz Tax Advisers
  • Article

    BVI, Costa Rica, Marshall Islands & Russia Added To The EU List Of Non-Cooperative Tax Jurisdictions

    On 14 February 2023, the EU Finance Ministers decided to add the BVI, Costa Rica, the Marshall Islands and Russia to the EU list of non-cooperative jurisdictions for tax purposes.
    GlobalTax
    Atoz Tax Advisers
    Atoz Tax Advisers
  • Article

    Luxembourg Tribunal Held That The Use Of Corporate Tax Losses Amounts To Abuse Of Law: What Went Wrong?

    On 30 March 2023, the Luxembourg Administrative Tribunal (Tribunal Administratif, the "Tribunal", which is the first instance jurisdiction) held its decision (the "Decision") in a case that concerns...
    LuxembourgTax
    Atoz Tax Advisers
    Atoz Tax Advisers
  • Article

    EU Commission's Initiatives In Direct Tax Matters: State Of Play

    On 15 December 2022, the EU Member States finally reached an agreement concerning the Directive on ensuring a global minimum level of taxation for multinational and large-scale domestic groups in the Union...
    European UnionTax
    Atoz Tax Advisers
    Atoz Tax Advisers
  • Article

    Upcoming FATCA - CRS Issues: What The Alternative Fund Industry Needs To Know

    The world of alternative investment funds was not the primary target of the Foreign Account Tax Compliance Act (FATCA) and Common Reporting Standard (CRS) norms.
    LuxembourgTax
    Atoz Tax Advisers
    Atoz Tax Advisers
  • Article

    New Measures For Luxembourg Investment Funds In The Context Of COVID-19

    Considering the development of the COVID-19 crisis, a number of new measures and communications have been issued to the attention of the financial centre over the past days.
    LuxembourgCoronavirus (COVID-19)
    Atoz Tax Advisers
    Atoz Tax Advisers

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