Latest Newsflashes
Jan 08, 2024Luxembourg Higher Administrative Court rules on debt/equity qualification of interest free loans for tax purposes
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
Jan 05, 2024OECD Pillar One | Amount A draft multilateral convention released
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
Jan 04, 2024Draft ECOFIN report to the European Council on tax issues November 2023 – ATAD 3
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
Jan 04, 2024European Council: Biannual update of the EU list of non-cooperative jurisdictions for tax purposes
On 17 October 2023, the European Council (the " Council") has updated the list of non-cooperative jurisdictions for tax purposes. Antigua and Barbuda, Belize and Seychelles have been added to the EU list of non-tax cooperatives jurisdictions. The EU List is published as an annex to the conclusions
Jan 03, 2024NPL Directive | Update on transposition into Luxembourg law
Directive (EU) 2021/2167 of 24 November 2021 on credit servicers and credit purchasers and amending Directives 2008/48/EC and 2014/17/EU (the “ Directive”) which will regulate the sale, purchase and servicing of non-performing loans originated by EU Banks should have been transposed in all Member
Dec 22, 2023Newsflash | CJEU judgement on VAT treatment of directors’ fees
On 21 December 2023, the Court of Justice of the European Union (“CJEU”) delivered its highly anticipated judgement following the preliminary ruling referral by a Luxembourg court regarding the VAT regime applicable to an individual acting as director of Luxembourg public limited liability companies
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