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Jul 07, 2026CJEU case I VAT treatment of loan servicing
On 17 June 2026, the General Court of the European Union handed down a judgment in case T-184/25 – Veronsaajien oikeudenvalvontayksikkö v A Oy on the VAT treatment of loan servicing. The judgment has significant implications for Luxembourg securitisation transactions. Facts of the case A Oy is the
Jul 07, 2026Transfer pricing and VAT | No taxable service without a direct legal nexus
In its judgment of 13 May 2026 in Case C-603/24 , Stellantis Portugal, S.A. (successor to General Motors Portugal (" GMP")) v Autoridade Tributária e Aduaneira , the Court of Justice of the European Union (" CJEU") confirmed that transfer pricing adjustments implemented to achieve a predetermined
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
Mar 17, 2026VAT | No fraudulent intent required for fines imposed under Article 77(3) of the VAT Law
In a judgment dated 5 February 2026, the District Court of Luxembourg (No. TAL-2023-09471) has confirmed a EUR 725,000 administrative fine imposed by the Luxembourg Registration Duties, Estates and VAT Authority ( Administration de l’enregistrement, des domaines et de la TVA ) (“ AED”) on a company
Mar 05, 2026MBT | Non-resident entities subject to municipal business tax only where a permanent establishment in Luxembourg is maintained, irrespective of legal form
In a judgment dated 3 March 2026 (No. 53701C ), the Higher Administrative Court ( Cour administrative, the “ Court”) dismissed an appeal brought by the Luxembourg State and confirmed that the Direct Tax Authority ( Administration des contributions directes , " DTA") had failed to establish the
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