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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

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

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

On 11 February 2026, the Lower Administrative Tribunal ( Tribunal administratif ) ruled in favour of a taxpayer-lawyer, holding that his 100% shareholding in a UK company did not form part of the net assets ( actif net investi ) of his law firm, and that the dividends received therefore qualified as

Background The European Commission has launched the Tax Omnibus initiative (the “ Initiative” or “ Tax Omnibus”) to simplify and modernise corporate direct taxation across the EU. The aim is to reduce administrative burdens, clarify rules, and increase the competitiveness of the internal market. The