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Oct 17, 2024ECJ Case law I Rules in favour of the Commission in Apple State aid case
On 10 September 2024, the ECJ ruled in favour of the EU Commission in case C-465/20 P, European Commission v Ireland and Apple Sales International relating to State aid granted by Ireland to Apple. Contrary to other State aid decisions involving transfer pricing, the ECJ accepted OECD transfer
Oct 16, 2024New circular of Luxembourg tax authorities | Clarifications on the tax-exempt rent subsidy for employees
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
Oct 10, 2024Newsflash | 2025 Luxembourg budget law | Temporary reduction of registration duties for real estate acquisitions
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
Jul 18, 2024Newsflash | Tax cuts and other measures announced for companies and individuals
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
Jul 10, 2024FASTER | Council of the European Union reaches political agreement
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
Jul 08, 2024Luxembourg Case Law | Abuse of law in the context of permanent establishments and interest free loans qualification
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 “
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