Newsflashes

On 20 December 2023, the law (the “ Pillar Two Law”) transposing Council Directive (EU) 2022/2523 of 15 December 2022 (the “ Pillar Two Directive”) has been adopted by the Luxembourg parliament, thus ensuring the Income Inclusion Rule (“ IIR”) and the Qualified Domestic Minimum Top-up Tax (“ QDMTT”)

The new Double Tax Treaty between the Grand Duchy of Luxembourg and the United Kingdom of Great Britain and Northern Ireland for the elimination of double taxation with respect to taxes on income and on capital and the prevention of tax evasion and avoidance (the “ DTT”), and the related protocol

On 22 December 2023, the Luxembourg parliament adopted the law ratifying the Protocol amending the Double Tax Treaty between Luxembourg and Germany (the “ DTT”), as agreed and signed on 6 July 2023 in Berlin (the “ Law”). The requirements for the entry into force of the above-mentioned Protocol

On 23 November 2023, the Luxembourg Higher Administrative Court handed down a decision regarding the tax qualification of an interest free loan (“ IFL”) granted by a parent company to a Luxembourg resident company. In the case at hand, a non-resident parent company granted its subsidiary, a

On 11 October 2023, the OECD released a draft multilateral convention (“ MLC”) in relation to Amount A of Pillar One. The draft reflects the current consensus achieved so far amongst members of the OECD/G20 Inclusive Framework on BEPS (“ IF”). On 18 December 2023, the OECD issued a statement

Background On 22 December 2021, the European Commission released a legislative proposal for a Council Directive (“ Draft Directive” or “ Draft ATAD 3”) laying down rules to prevent the misuse of shell entities for tax purposes and amending Directive 2011/16/EU on administrative cooperation in the