Latest Newsletters & Newsflashes
Jul 07, 2021Infographic | Direct and indirect tax deadlines for funds
An infographic to summarise fiscal deadlines for funds in Luxembourg.
Jun 21, 2021ECJ judgment on scope of VAT exemption for special investment fund management services
Following two preliminary references from Austrian courts, the European Court of Justice (“ ECJ”) ruled in a judgment handed down on 17 June 2021 that certain tax services and the granting of a license for risk-management software may fall within the VAT exemption for the management of special
Jun 21, 2021G7 nations agree to set a global minimum corporate tax rate at 15%
Introduction On 5 June 2021, the G7 had a summit in London during which the Finance Ministers agreed on the implementation of a global corporate minimum tax of 15% (the “ global minimum tax rate”) as detailed in a Communiqué released shortly thereafter (the “ G7 Communiqué”). Although the
Jun 21, 2021Circular on tax deductibility of certain expenses made by individuals
On 4 June 2021, the Director of the Luxembourg tax authorities issued circular LIR No.105/2 regarding the tax treatment of certain expenses incurred by individuals (the “ Circular”). GENERAL TAX TREATMENT OF EXPENSES BORNE BY INDIVIDUALS Before entering into more details as described below, the
Jun 14, 2021Proposed changes to Commentaries in the OECD Model Tax Convention
The Working Group on Tax Conventions and Related Questions (the “ Working Group”) of the Organisation for Economic Co-operation and Development (the “ OECD”), the subsidiary body of the OECD Committee on Fiscal Affairs in charge of the Model Tax Convention, has recently undertaken work to amend the
Jun 09, 2021Provisional agreement on public country-by-country reporting
CONTEXT On 1 June 2021, public country by country reporting (“ CbCR”) has been proposed as an amendment to the Accounting Directive 2013/34/EU (the “Accounting Directive”) through the introduction of a proposed directive on the disclosure of income tax information by certain undertakings and
Jun 01, 2021Extension of teleworking for Belgian, French and German cross-border workers in the context of the Covid-19 pandemic
As previously detailed, inter alia, in our newsflash dated 19 March 2020 (as updated), the Luxembourg Government has once again found an agreement on the “exceptional measures” put in place with the Belgian, French and German Governments regarding the taxation of cross-border commuters normally
May 31, 2021Communication of the European Commission on business taxation for the 21st century
The European Commission has taken the opportunity in the post-pandemic context to publish a communication on 18 May 2021 in which it sets out its future projects in the field of taxation in the European Union. The communication contains both short and long-term measures that take into account not
May 20, 2021Newsflash | Luxembourg publishes updated guidance on mutual assistance procedure in tax matters
On 11 March 2021, the Luxembourg Tax Administration (“ LTA”) published updated guidance on the Mutual Assistance Procedure (“ MAP”) in tax matters provided for in double tax conventions signed by Luxembourg. The guidance, which replaces circular L.G.Conv. D.I n o 60 of 28 august 2017, describes the
May 17, 2021Lower Administrative Court finds MPRS qualify as equity for tax purposes
On 10 May 2021, the Lower Administrative Court ( Tribunal administratif) handed down a judgment addressing (a) the equity/debt qualification for tax purposes of Mandatorily Redeemable Preferred Shares (“ MRPS”) and (b) whether a shareholding in a French Société à Prépondérance Immobilière à Capital
Apr 01, 2021Newsflash | Luxembourg implemented new tax provisions limiting deductibility of costs incurred in non-cooperative jurisdictions
On 8 January 2021, the Luxembourg Parliament voted to approve the Bill N°7547 (the “ Bill”) implementing new provisions (with effect as from 1 March 2021) related to tax deductions vis-à-vis interest and royalty expenses (the “ Law”) owed to affiliated corporations established in jurisdictions
Mar 26, 2021The value of the principle of retroactivity according to the Constitutional Court
In its judgment of 22 January 2021, the Luxembourg Constitutional Court had the opportunity to rule on the value of the principles of legal certainty, protection of legitimate expectations and non-retroactivity of laws when assessing the conformity of the law of 23 July 2016 amending, inter alia
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