Law Firm ILN-telligence Podcast | Episode 38: Pierre Hurt, Lutgen & Associés | Luxembourg
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
La Cour administrative d'appel de Nancy a rendu deux arrêts le 24 avril 2025 éclairant les indices nécessaires afin de prouver la réalité des prestations faisant l'objet d’une convention de management fees (CAA Nancy, 24...more
The Specialised Investment Fund (SIF) regime was established in Luxembourg by the Law of 13 February 2007 (the “SIF Law”). The SIF regime’s purpose was to offer great flexibility on investment scope while structuring and...more
The below summary deals with the most relevant Luxembourg corporate and individual tax measures proposed in 2024, which cover, among others, the decrease of the corporate income tax rate, the introduction of a subscription...more
On July 17, 2024, the Luxembourg Minister of Finance submitted Bill of Law #8414 to the Luxembourg Parliament. The Bill proposes a series of tax measures aiming to make Luxembourg a more attractive place to work, do business...more
On 17 July 2024, the Luxembourg government introduced, under new Bill n° 8414, a comprehensive legislative package meant to modernise and enhance Luxembourg’s tax system. ...more
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
On 4 August 2023, Luxembourg published a bill of law (the “Bill”) to transpose the EU directive no. 2022/2523 largely known as the “EU Minimum Tax Directive” or “Pillar Two Directive”, ensuring a minimum global Effective Tax...more
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
On 12 October 2022, the finance minister presented the Luxembourg budget bill for fiscal year 2023. For corporate tax payers, and particularly for funds, there is a most welcomed clarification on the scope of the...more
On March 31, 2022, the Luxembourg Administrative Court of Appeal ruled that, in order to determine the minimum acquisition value of a participation for the purposes of the Luxembourg parent-subsidiary exemption, the...more
Ein erster Erfahrungsbericht - Mit Inkrafttreten des Fondsstandortgesetzes (FoStoG) am 2. August 2021 hat der Gesetzgeber das geschlossene Sondervermögen als neue Anlagemöglichkeit im Spezialfondsbereich geschaffen. So...more
The Luxembourg law on securitisation dated 22 March 2004 (the “Securitisation Law”) has been tremendously successful in providing a flexible and secure framework for Luxembourg securitisation vehicles (“SVs”), attracting a...more
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
On 8 January 2021, the Luxembourg Tax Authorities published a Circular clarifying the interest limitation rules introduced in Luxembourg legislation in 2018, which implemented the European Union Anti-Tax Avoidance Directive...more
In Wisconsin Department of Revenue v. Deere & Company, the Department of Revenue tried to disallow a dividends received deduction for distributions from a Luxembourg entity despite published guidance conflicting with its...more
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
On 8 January, 2021, the Luxembourg tax authorities published Circular L.I.R. 168bis/1 on interest limitation rules (the “Circular”). The Circular provides much needed clarity to the interest limitation rules which have...more
The much-awaited Luxembourg state budget for FY 2021 has finally been tabled before the Chamber of Deputies. Delayed due to the ongoing COVID-19 pandemic, the Luxembourg government published bill number 7666 on 14 October...more
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
On September 24, 2019, the EU General Court (General Court) issued its long-awaited judgments in relation to the appeals brought against two European Commission (EC) decisions of 2015 concluding that tax rulings granted by...more
The law dated 7 March 2019 approving the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (Multilateral Instrument or MLI) was published in the Luxembourg Mémorial...more
The Tax Court of Canada recently held, in Alta Energy Luxembourg SARL v R, 2018 TCC 152, that a Luxembourg S.A.R.L was entitled to treaty benefits on capital gains and that the general anti-avoidance rule ("GAAR") did not...more
On 14 December 2017, the Luxembourg Parliament (Chambre des Députés) approved the draft law (n° 7200) on the 2018 budget including certain tax measures (the "Law"). ...more
UK Tax News and Developments - Government White Paper on Customs Bill - On 9 October, the Government published a White Paper setting out its approach to the introduction of a new customs and VAT regime after the UK...more