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International Tax Issues Luxembourg

Herbert Smith Freehills Kramer

Luxembourg Reverse Hybrid Entity Rules: Clarifications Regarding the CIV Exemption

On 22 August 2025, the Luxembourg tax authorities issued a second circular (Circular) on the reverse hybrid entity rules, this time clarifying the exemption applicable to collective investment vehicles (CIV Exemption)....more

White & Case LLP

Important Tax Update: Luxembourg Court Decision on Interest Free Loans and Debt to Equity Ratio – A Global Impact

White & Case LLP on

International transactions, such as private equity deals, mergers and acquisitions, and financing arrangements, frequently leverage Luxembourg entities as holding companies or joint ventures. It is common for such companies...more

Goodwin

Pillar II in Luxembourg: What Investment Funds Need to Know

Goodwin on

The implementation of the Organisation for Economic Co-operation and Development’s (OECD’s) Pillar II rules in Europe, and in the Luxembourg law on 22 December 2023 (the Pillar II Law) in particular, has been a major...more

K&L Gates LLP

The Inside Basis: Tax Insurance in Luxembourg

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In our second episode of The Inside Basis, Randy Clark is joined by Marion Zeller, a tax partner in our Luxembourg office, and David Mussche, an associate director with Howden M&A's tax team, to discuss the state of tax...more

White & Case LLP

Luxembourg Tax Update: Key Takeaways from Prime Minister Luc Frieden’s State of the Nation Address

White & Case LLP on

In his State of the Nation Address on June 11, 2024, Luxembourg Prime Minister Luc Frieden introduced several significant fiscal policy initiatives aimed at enhancing the country’s attractiveness to international businesses...more

A&O Shearman

Luxembourg tax administration issues guidance on the tax treatment and reporting obligations of reverse hybrid entities

A&O Shearman on

On 9 June 2023, the Luxembourg tax administration (the LTA) issued circular L.I.R. n°168quater/1 (the Circular) providing long-awaited guidance on the application of article 168quater of the Luxembourg Income Tax Law (the...more

Hogan Lovells

All roads lead to Luxembourg – why the Grand Duchy matters to Asia Pacific private capital

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Luxembourg is the largest centre for funds in the world outside the United States (U.S.). The country offers much for Australian PE investors. We look at what makes it so attractive....more

BCLP

Delay to Luxembourg-UK treaty changes - impact on UK real estate

BCLP on

Unexpectedly, it is likely the changes to the Luxembourg-UK double tax treaty will not be effective until 2024 at the earliest. Where that is the case, some Luxembourg investors in UK property rich entities will have another...more

Skadden, Arps, Slate, Meagher & Flom LLP

EU Court of Justice Faults European Commission for Expansive Interpretation of State Aid in Tax Rulings

On November 8, 2022, the Court of Justice of the European Union (CJEU), overturning the first instance EU General Court (General Court), annulled the European Commission’s (EC’s) decision that a Luxembourg tax ruling on...more

Goodwin

Luxembourg AIFMs - Post-Pandemic Teleworking Practices

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The COVID-19 agreements regarding taxation and social security legislation for cross-border workers working remotely enacted by Luxembourg with Belgium, Germany and France ended on 30 June 2022. What is the legal...more

A&O Shearman

The new Luxembourg/United-Kingdom tax treaty has been signed.

A&O Shearman on

More than four years after the announcement of negotiations, the new tax treaty between Luxembourg and the United Kingdom was finally signed on 7 June 2022, together with a Protocol adding further detail. As expected, the new...more

Goodwin

The UK and Luxembourg Signed A New Double Tax Treaty

Goodwin on

On 7 June 2022, a new Double Tax Treaty (the “DTT”) has been signed between Luxembourg and the United Kingdom (UK) to reflect the most recent OECD tax standard. An additional protocol will replace the tax treaty signed in...more

Faegre Drinker Biddle & Reath LLP

Luxembourg Extends Cross-Border Tax and Social Security Agreements with Neighboring Countries

Over the past fifteen months, many countries have introduced creative new approaches to address the economic realities of the COVID-19 pandemic. As employees continue to work remotely and employers reconsider whether...more

Goodwin

Luxembourg: Potential Impacts Of The Global Minimum Tax

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On 4 and 5 June 2021, the Finance Ministers and Central Bank Governors of the G7, joined by the Heads of the International Monetary Fund, World Bank Group, Organisation for Economic Cooperation and Development, and Eurogroup,...more

Goodwin

Luxembourg Tax Authority Issues New Guidance On Mutual Agreement Procedure

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On 11 March 2021, the Luxembourg Tax Authorities published a Circular providing guidance on the process for initiating the mutual agreement procedure (“MAP”) under bilateral income tax treaties and explaining the interaction...more

Goodwin

Luxembourg: The EU Parent Subsidiary Directive And Gibraltar

Goodwin on

On 1 December, 2020, the Luxembourg tax authorities issued circular L.I.R 147/2, 166/2 and eval. n°63 on the application of EU Directive 2011/96 on the common system of taxation applicable in the case of parent companies and...more

Hogan Lovells

Second extension of the temporary measures allowing for virtual meetings of corporate bodies

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The law of 20 June 2020 extended the measures concerning the holding of meetings in companies and other certain legal persons without the physical presence of the participants, initially provided for in the Grand Ducal...more

Epstein Becker & Green

Luxembourg’s Teleworking Agreements with Neighboring Countries Remove Tax and Social Security Burdens During the COVID-19 Pandemic

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As we have previously highlighted, many countries have introduced creative new approaches to address the economic realities of the COVID-19 pandemic. As employees continue to work from home and employers reconsider whether...more

Jones Day

France and Luxembourg Sign New Tax Treaty

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The Situation: On March 20, 2018, the governments of France and Luxembourg signed a new double tax treaty that will replace the current tax treaty dated April 1, 1958 (as amended through 2014). The Result: The most...more

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