Newsletters & Newsflashes

On 5 January 2026, the OECD Inclusive Framework issued additional guidance on the application of the Global Anti-Base Erosion Model Rules (“ Pillar Two” or the “ GloBE Rules”). This guidance covers several topics, most notably the “Side-by-Side Safe Harbour”, which is currently applicable to US

In its judgment of 17 September 2025, the Lower Administrative Court ( Tribunal administratif) delivered a significant decision (n° 47603) on permanent establishment determination and commercial profit characterisation for non-resident professional service providers. The Court ruled that the

Background On 4 September 2025, Advocate General Kokott (AG Kokott) delivered her Opinion in the case C-121/24, Vaniz EOOD , on the conditions under which a third party may be held jointly and severally liable for unpaid VAT under national law, based on EU VAT legislation. The case at hand concerned

On 8 October 2025, the Luxembourg Minister of Finance presented the 2026 budget (the “ Budget Law”) oriented towards growth and social cohesion. The Budget Law provides for significant investments in innovation and infrastructure. On the tax side, it sets the 2026 agenda and has been complemented by

On 2 October 2025, the Higher Administrative Court ( Cour administrative) issued a ruling in case n° 51646C (the “ Decision”), regarding the extent to which a former manager of a Luxembourg resident company called in guarantee may challenge the underlying tax assessments of that company. While the

On 8 October 2025, Draft Law No. 8633 was submitted to the Luxembourg Parliament ( Chambre des Députés) (the “ Draft Law”) to introduce a new tax exemption on interest earned by Luxembourg resident individuals on certain specific bonds issued by a State. To meet its NATO defence spending commitments

Background On 4 April 2025, Draft Law No. 8526 (the “ Draft Law”) was submitted to the Luxembourg Parliament ( Chambre des Députés ) and intends to introduce, as from fiscal year 2026, a tax credit for private individuals investing in Luxembourg startups amounting to 20% of their equity investment

In July 2025, the Luxembourg government drew up a draft Grand-Ducal Regulation (the “ Draft Regulation”) amending the Grand-Ducal Regulation of 9 January 1974 on the determination of tax withholding on salaries and pensions (the “ Regulation”). Context: flat-rate withholding tax for occasional work

On 4 September 2025, the ECJ delivered its decision in the Arcomet case ( C-726/23) following a request for preliminary ruling on whether intragroup remuneration adjustment for services, determined under the transfer pricing (“ TP”) Transactional Net Margin Method (“ TNMM”), is subject to VAT and

Key takeaways On 6 August 2025, the Luxembourg Higher Administrative Court ( Cour administrative ) handed down a decision (n °52321C ) whereby taxpayers cannot themselves request an ex-post review following the filing of an inaccurate tax return. From the Court’s perspective, the decision to carry

On 31 July 2025, the Belgian Constitutional Court referred a request for a preliminary ruling to the European Court of Justice (the “ ECJ”) on the compatibility of Council Directive 2022/2553 of 14 December 2022 on ensuring a global minimum level of taxation for multinational enterprise groups and

On 22 August 2025, the Luxembourg Tax Authorities (hereafter the “ LTA”) published the administrative circular L.I.R. n°168 quater /2 (the “ Circular”) clarifying the requirements to be met by collective investment vehicles (“ CIV”) to benefit from the exemption from the reverse hybrid rule