Newsletters & Newsflashes

In a judgment dated 17 March 2022, the Luxembourg Higher Administrative Court ( Cour administrative) ruled that tax assessments issued by the Luxembourg Tax Administration (“ LTA”) must adequately explain the reasons justifying the position taken therein in order to enable the taxpayer to understand

The Luxembourg tax authorities issued a circular on 8 January 2021 on the interest deduction limitation rules (“ ILR”) as foreseen in Article 168bis of the Luxembourg income tax law (“ LITL”). The original circular was already amended several times ( Circulaire du directeur des contributions L.I.R

On 22 March 2022 the Organisation for Economic Co-operation and Development (“ OECD”) released a public consultation document concerning a new global tax transparency framework to provide for the reporting and exchange of information with respect to crypto-assets, as well as proposed amendments to

As previously detailed in our newsflash dated 19 March 2020 (as updated), the Luxembourg Government has once again agreed on an “exceptional measure” with the Belgian, French and German Governments regarding the taxation of Belgian, French and German cross-border commuters normally working in

On January 20 th 2022, the Luxembourg tax authorities (“ LTA”) issued circular PRE_IMM n° 1 (the “ Circular”), regarding the 20% real estate levy (the “ Real Estate Levy”) introduced by the Luxembourg law of 19 December 2020 (the “ Law”) and applicable since fiscal year 2021. The aim of the Circular

On 9 March 2022, the Luxembourg Ministry of Finance published the draft law No.7974 (the “ Draft Law”) which relates to the interest limitation rules. The purpose of the Draft Law is to amend Article 168bis of the Luxembourg income tax law (“ LITL”) by removing the reference to securitisation

Context The Luxembourg Supreme Court ( Cour de cassation), through its decision on 3 February 2022 (No. Cas-2020-00163), overruled a judgment issued by the Court of Appeal ( Cour d’Appel) on 8 July 2020 (No. 97/20-VII-CIV) and confirmed that a stay of execution ( sursis à exécution) granted by the

On 11 November 2021, the Higher Administrative Court ( Cour administrative) issued a judgment on an appeal lodged by a taxpayer against a judgment of the Lower Administrative Court ( Tribunal administratif) that deemed a case lodged before it as inadmissible due to the fact that it was filed by a

As previously detailed in our newsflash dated 19 March 2020 (as updated), the Luxembourg Government has once again secured an agreement on “exceptional measures” with the Belgian, French and German Governments regarding the taxation of Belgian, French and German cross-border workers, who would

Overview On 20 December 2021, the OECD released detailed rules, the so-called Global Anti-Base Erosion (“ GloBE”) rules under BEPS 2.0 - the Pillar Two Model (" Pillar Two Model”), to assist in the implementation of a global minimum 15% tax rate to Multinational Enterprises (“ MNEs”) applicable as

In a judgment dated 30 November 2021, the Luxembourg Lower Administrative Court ( Tribunal administratif) ruled that a taxpayer may not successfully modify a material error in his financial accounts in a way that has the effect of amending financial accounts of a previous year for which a tax

Overview 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