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On 22 July 2026, the Luxembourg Higher Administrative Court ( Cour administrative ) (the “ Court”) (No. 53194C ) clarified the framework to assess the arm’s length character of a debt restructuring as well as the rules applicable to the accounting of debt and related interest for tax purposes. Facts

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

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

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

In a judgment dated 25 March 2026, the Luxembourg Lower Administrative Court ( Tribunal administratif) ruled that distributions from a share premium reserve, undertaken in the absence of a formal share capital reduction, are prima facie subject to Luxembourg withholding tax (“ WHT”) and do not

The 2025 update to the OECD Model Tax Convention , published in November 2025, is the first comprehensive revision since 2017. The update notably provides clarification to the Commentary of Article 5 on when a home office of a cross-border worker may constitute a permanent establishment. Why this