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On 17 April 2025, the Luxembourg Higher Administrative Court ( Cour administrative), delivered its long awaited decision on case n° 50.602C pertaining to the qualification of interest free loans under Luxembourg tax law and the existence of a permanent establishment in a treaty jurisdiction. With

On 3 March 2025, the government issued a draft Grand-Ducal Decree amending the existing Grand Ducal-Decree of 13 February 2018 implementing Article 4, paragraph 2, of the law of 23 December 2016 on Country-by-Country Reporting (“ CbCR”), the purpose of which is to update the list of ‘Reportable

On 29 January 2025, the Luxembourg Tax Authorities (“ LTA”) issued a new Circular LITL No. 164/1 (the “ New Circular”), replacing Circular LIR No. 164/1 dated 23 March 1998 (the “ Previous Circular”) on the interest rates related to current account of associates or shareholders of entities subject

On 4 October 2024, the European Court of Justice (the “ ECJ”) (Case C-585/22) ruled that Article 49 of the Treaty on the Functioning of the European Union (the “ TFEU”), which guarantees the freedom of establishment, does not preclude national legislation from fully denying the deduction of interest

On 1 August 2024, the European Commission released a draft regulation to standardize multinational enterprises (“ MNEs”) income tax information for public Country-by-Country Reporting (“ CbCR”), as required by Directive 2013/34/EU. The proposal introduces a common template and electronic formats to

On 8 May 2024, the Luxembourg Lower Administrative Tribunal (the “ Tribunal”) (n° 47267) ruled on the tax qualification of interest-free loans (“ IFLs”) granted by a parent company to a Luxembourg subsidiary (the “ Company”) as well as the non-existence of a Malaysian permanent establishment (the “