Newsletters & Newsflashes

Key takeaways In a decision ( no. 50199C ), dated 17 July 2024 the Higher Administrative Court ( Cour administrative ) upheld a decision by the Director of the Luxembourg tax authorities (“ LTA”), who in a specific case denied the valuation of convertible bonds issued by a Luxembourg tax-resident

On 27 September 2024, the Luxembourg tax authorities issued Circular n° 115/14 clarifying certain aspects of the partially tax-exempt rent subsidy which has been introduced by the law of 22 May 2024 and applicable since 1 st June 2024 ( see our previous newsflash). Background The rent subsidy

On 9 October 2024, Luxembourg’s Finance Minister submitted draft budget law No. 8444 to the Luxembourg Parliament (the “ Draft Budget Law”). The main tax measure is the reduction by fifty percent of the taxable basis for registration and transcription duties applicable to real estate acquisitions

On 19 July 2024, Luxembourg direct tax authorities issued circular L.I.R. n° 170/1, 170bis/1, I.C.C. n° 44, I.Fort. n° 55 (the “ Circular”) clarifying the Luxembourg tax treatment of the dissolution without liquidation under art. 1865 bis of the Civil Code (also called in practice simplified

On 15 July 2024, the Luxembourg indirect tax authorities issued Circular n° 821 notifying the issuance of new online forms via MyGuichet.lu for the quarterly subscription tax returns of undertakings for collective investments (“ UCI”), specialized investment funds (“ SIF”), and reserved alternative

On 17 July 2024, draft law No. 8414 has been submitted to the Luxembourg Parliament ( Chambre des Députés) (the “ Draft Law”) introducing new tax measures and enhancing certain existing tax regimes. The Draft Law focuses on competitiveness and attractiveness for Luxembourg companies, investors and

Key takeaways On 13 June 2024, the European Court of Justice (“ ECJ”) issued its ruling in case C-533/22 ( Adient case) pertaining to whether an affiliated undertaking may be regarded as a fixed establishment of another foreign group company for VAT purposes. Facts of the case Adient group is a

Background As a reminder, on 19 June 2023, the European Commission released a proposal for a Council Directive on Faster and Safer Relief of Excess Withholding Taxes (“ FASTER Proposal”) laying down rules on the issuance of a digital tax residence certificate by EU Member States and the procedure to

On 8 May 2024, the Luxembourg Lower Administrative Tribunal (the “ Tribunal”) (n° 47267) ruled on the tax qualification of interest-free loans (“ IFLs”) granted by a parent company to a Luxembourg subsidiary (the “ Company”) as well as the non-existence of a Malaysian permanent establishment (the “

Update to Pillar Two legislation On 12 June 2024, draft law No. 8396 has been submitted to the Luxembourg Parliament ( Chambre des Députés ) (the “ Draft Law”) proposing amendments to the Luxembourg law on Pillar Two (see our previous newsflash on the Pillar Two law). Council Directive (EU) 2022

On 11 June 2024, Prime Minister Luc Frieden delivered before the Luxembourg Parliament ( Chambre des Députés) his first general policy statement on the state of the nation (the “ Statement”). In his Statement, the Prime Minister announced specific and general tax measures to be adopted within the

In a decision dated 21 March 2024 (no. 49678C), the Higher Administrative Court upheld a decision by the Director of the Luxembourg tax authorities (“ LTA”), who in a specific case refused to apply the final withholding tax on savings income in the form of interest payments made in Luxembourg to