Latest Newsflashes
Feb 27, 2025Simplified procedure for the creation of new share classes
On 12 February 2025, the CSSF introduced a new simplified procedure for creating new share classes that do not require a prospectus update. This applies to UCITS, UCI Part II, SIFs, and SICARs. The key points include that : the procedure is available only for share classes whose characteristics are
Feb 04, 2025Newsflash | New Luxembourg Circular on interest rates on shareholders’ current accounts
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
Jan 30, 2025Key changes in the Luxembourg tax landscape for 2025
Significant changes have taken place in the Luxembourg tax landscape in the course of the year 2024, as demonstrated by the intense legislative activity until the last days of 2024, with several measures taking effect as from fiscal year 2025, as summarised below. Corporate taxpayers Corporate
Jan 30, 2025European Court of Justice denies the tax deduction of (arm’s length) interest expenses in the context of a non-genuine arrangement
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
Jan 30, 2025VAT I New circular and procedure for the reimbursement of VAT on director fees
On 11 December 2024, the Luxembourg Indirect Tax Authorities ( Administration de l’enregistrement, des domaines et de la TVA) issued a new circular No. 781-2 on the VAT treatment of director’s fees following the decision of the European Court of Justice (the “ ECJ”) in case C-288/22, TP v
Jan 30, 2025Luxembourg Case Law I Compliance with the principle of adversarial proceedings in relation to fines for tax offences
On 16 October 2024, the Lower Administrative Court ( Tribunal administratif ) annulled a decision by the Director of the Luxembourg Tax Authorities (“ LTA”) ( Administration des contributions directes) to uphold and increase the amount of a fine imposed by the Tax Office on a tax consultancy company
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