Latest Newsletters & Newsflashes
Jul 07, 2026Transfer pricing | Proposed revision to Chapter VII of the OECD Guidelines on intra-group services
On 18 June 2026, the OECD released a Public Consultation Document proposing a revision of Chapter VII of the OECD Transfer Pricing Guidelines (“T P Guidelines”) on intra-group services, which seeks to align the existing guidance with the foundational principles set out in Chapters I-III. The
Jul 07, 2026Net wealth tax | Deductibility of intragroup debts arising from a tax-sharing agreement
In a judgment of 20 May 2026 (No. 48972 ), the Lower Administrative Court ( Tribunal administratif , the “ Tribunal”), Fifth Chamber, overturned a decision of the Direct Tax Administration (the “ DTA”) and ruled that debts recorded by a Luxembourg subsidiary under a private-law tax-sharing agreement
Jul 07, 2026Single Tax Class reform I Governmental amendments to the Draft Law
Key takeaways On 9 June 2026, the Luxembourg Government submitted eleven amendments to draft law No. 8676 introducing the Single Tax Class and individual taxation as the default personal income tax regime from 2028 onwards. The amendments follow the Council of State’s opinion of 5 May 2026 and
Jul 07, 2026BSP Newsletter | July 2026
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Jul 02, 2026Newsflash | Luxembourg Draft Law No 8782: New Tax Regime defers stock option taxation to share disposal for innovative start-ups
The Luxembourg Government filed Draft Law No 8782 (the " Draft Law") with the Luxembourg Parliament ( Chambre des Députés ) on 1 July 2026, proposing a comprehensive reform of the tax regime applicable to employee stock option plans under the Luxembourg Income Tax Law of 4 December 1967, as amended
Jun 29, 2026Newsflash | CPECs confirmed as debt instruments on appeal: dividend rules do not apply
A decade in the making When the Luxembourg District Court ( tribunal d’arrondissement ) delivered its judgment on 23 December 2015 in the Hellas Telecommunications litigation, the case had attracted extraordinary attention, both for its international dimension – involving Luxembourg, the United
Jun 02, 2026Newsflash | Act II before the CJEU: following the 2022 judgement, the RBE saga resumes
May 2026 – The debate surrounding Luxembourg's Register of Beneficial Owners (RBO) is far from over. In an order dated 29 May 2026, the Luxembourg District Court has just decided to refer several fundamental questions for a preliminary ruling on the interpretation of Directive (EU) 2024/1640 back to
May 28, 2026Infographic | Luxembourg start-up investment tax credit
As from tax year 2026, the start-up investment tax credit offers individual investors a 20% tax credit on qualifying equity investments in innovative young companies, effective from the 2026 tax year. Eligible investors Resident individual taxpayers in Luxembourg; and Non-resident individual
May 15, 2026Luxembourg Transfer Pricing Case Law | Undisclosed counter-guarantee subjected to TP adjustment
On 18 March 2026, the Luxembourg Administrative Tribunal ( Tribunal administratif, No. 48905) ruled on the TP implications of an intra-group financing operated through a Luxembourg PE involving guarantees. Following a Belgian tax adjustment and a spontaneous exchange of information, the Luxembourg
Apr 22, 2026Our latest publications
Newsflash | Luxembourg case law | Share premium reimbursement without capital reduction subject to withholding tax Infographic | Luxembourg impatriate tax regime for highly skilled employees Infographic | Luxembourg's carried interest tax regime Thomson Reuters Practical Law | Arbitration procedures
Apr 22, 2026Sustainable finance | CSSF updates its supervisory priorities for 2026
The CSSF reinforces its sustainable finance agenda across all supervised sectors In a communiqué dated 2 March 2026, the CSSF has updated its priorities within the area of sustainable finance. The CSSF believes that sustainability considerations and the integration of sustainability risks should not
Apr 21, 2026Omnibus I Directive | CSRD simplification
On 24 February 2026, the European Union (“EU”) adopted Directive (EU) 2026/470 (the “Directive”), amending, inter alia, Directive 2006/43/EC, Directive 2013/34/EU, Directive (EU) 2022/2464 and Directive (EU) 2024/1760, with a view to strengthening corporate sustainability reporting and due diligence
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