Latest Newsletters & Newsflashes
Jan 18, 2024Shadow Banking and CRR Reporting | New Delegated Regulation
New technical standards for identification of shadow banking entities On 12 December 2023, Commission Delegated Regulation (EU) 2023/2779 of 6 September 2023 was published (the " New Delegated Regulation"). The New Delegated Regulation supplements Regulation (EU) 575/2013 (the “ Capital Requirements
Jan 17, 2024Transparency Law | CSSF enforcement priorities
Background On 8 January 2024, the CSSF published a press release for the attention of issuers of securities subject to the law of 11 January 2008 on transparency requirements for issuers of securities, as amended (the " Transparency Law") and their auditors (the " Press Release"). With this Press
Jan 17, 2024Luxembourg Constitutional Court: the absence of precise legal criteria for the allocation and contribution of funds to and by municipalities is contrary to the principle of municipal autonomy
In four rulings dated 17 November 2023, the Luxembourg Constitutional Court answered preliminary questions put to it in disputes involving the municipalities of Leudelange and Niederanven. The question relates to the definition of the concept of “adjusted population” ( population ajustée), which is
Jan 16, 20242024 Social election
On the 20 November 2023, the Ministerial Decree of 13 October 2023 setting the date for the renewal of staff delegations for the period 2024 to 2029 was published on the Luxembourg Official Gazette. Any Luxembourg company, regardless of the nature of its activity, which employs at least 15 employees
Jan 15, 2024New rules for the Luxembourg investments tax credit
As from fiscal year 2024, new rules apply to the Luxembourg investment tax credit (“ ITC”) mechanism provided by Article 152 bis of the Luxembourg income tax law (“ LITL”). The mechanism has been revised, and its benefits extended to investments and expenses incurred in the context of digital
Jan 15, 2024EU interconnected check of director’s position
On 24 November 2023, draft law No. 8342 transposing directive (EU) 2019/1151 of 20 June 2019 amending directive (EU) 2017/1132 as regards the use of digital tools and processes in company law and amending the amended law of 19 December 2002 on the register of commerce and companies and the
Jan 11, 2024Pillar Two | Subject to tax rule multilateral convention
On 3 October 2023, the OECD published the multilateral convention (“ MLC”) to facilitate the implementation of the Pillar Two Subject to Tax Rule (“ STTR”) together with an explanatory statement. The STTR is part of Pillar Two together with the GloBE Rules (i.e., Income Inclusion Rule and Undertaxed
Jan 10, 2024Pillar Two enters into force in Luxembourg
On 20 December 2023, the law (the “ Pillar Two Law”) transposing Council Directive (EU) 2022/2523 of 15 December 2022 (the “ Pillar Two Directive”) has been adopted by the Luxembourg parliament, thus ensuring the Income Inclusion Rule (“ IIR”) and the Qualified Domestic Minimum Top-up Tax (“ QDMTT”)
Jan 09, 2024Luxembourg-UK Double Tax Treaty | Entry into Force
The new Double Tax Treaty between the Grand Duchy of Luxembourg and the United Kingdom of Great Britain and Northern Ireland for the elimination of double taxation with respect to taxes on income and on capital and the prevention of tax evasion and avoidance (the “ DTT”), and the related protocol
Jan 08, 2024Luxembourg-Germany Double Tax Treaty | Law ratifying the amending Protocol adopted and additional clarifications
On 22 December 2023, the Luxembourg parliament adopted the law ratifying the Protocol amending the Double Tax Treaty between Luxembourg and Germany (the “ DTT”), as agreed and signed on 6 July 2023 in Berlin (the “ Law”). The requirements for the entry into force of the above-mentioned Protocol
Jan 08, 2024Luxembourg Higher Administrative Court rules on debt/equity qualification of interest free loans for tax purposes
On 23 November 2023, the Luxembourg Higher Administrative Court handed down a decision regarding the tax qualification of an interest free loan (“ IFL”) granted by a parent company to a Luxembourg resident company. In the case at hand, a non-resident parent company granted its subsidiary, a
Jan 05, 2024OECD Pillar One | Amount A draft multilateral convention released
On 11 October 2023, the OECD released a draft multilateral convention (“ MLC”) in relation to Amount A of Pillar One. The draft reflects the current consensus achieved so far amongst members of the OECD/G20 Inclusive Framework on BEPS (“ IF”). On 18 December 2023, the OECD issued a statement
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