Newsletters & Newsflashes

In a judgment dated 7 February 2024 ( docket No. 46783 ), the Luxembourg Lower Administrative Court ( Tribunal administratif ) (the “ Court”) handed down a decision concerning the application of the provisions of Article 157 ter of the Luxembourg income tax law (“ LITL”), allowing non-resident

Following the entry into force of the Luxembourg law of 7 August 2023 on business continuation and modernisation of bankruptcy law (the “ Law”) on 1 November 2023, the Luxembourg courts have handed down several decisions clarifying the scope of application of judicial reorganisation proceedings, the

On 14 February 2024, the Council and the European Parliament have reached a preliminary agreement on the directive on multiple-vote share structures in companies that seek the admission to trading of their shares on an SME growth market (the “ Proposed Directive”). The Proposed Directive is part of

Newsflash | Pillar Two - The Luxembourg Tax Authorities issue a first FAQ Newsflash | Tax measures in favour of the Luxembourg real estate sector

On 19 February 2024, the OECD/G20 Inclusive Framework (“ IF”) on BEPS released its report on Amount B of Pillar One intended to simplify transfer pricing aspects of baseline marketing and distribution activities, alleviate administrative burden, cut compliance costs, and enhance tax certainty

Urgent need to implement harmonized transfer pricing framework for the EU according to ECON On 22 February 2024, the Economic Monetary Affairs Committee (“ ECON”) of the European Parliament adopted its opinion on the European Commission’s (“ EC”) proposal for a Directive on transfer pricing (“ TP

On 19 February 2024, the OECD Council allowed an update to the Commentary 26 of the OECD Model, which relates to the exchange of information, more specifically to the question of administrative assistance. As a reminder, the exchange of information process was set up in 2009 in order to improve the

On 6 th March 2024, the Luxembourg government filed the 2024 budget bill (“ Budget Bill”) and announced that it will continue to work towards the implementation of a tax policy aimed at strengthening the competitiveness of the economy and increasing household purchasing power. While certain measures

In a judgment of 11 January 2024, the Luxembourg Higher Administrative Court annulled tax assessments issued to a taxpayer for breach of the adversarial principle set out in §205(3) AO (the Abgabenordnung ), which foresees the right for the taxpayer to be heard by the tax office before issuance of

On 20 February 2024, the European Council updated the list of non-cooperative jurisdictions for tax purposes. This list was previously updated on 17 October 2023 (please refer to our newsletters here for more details). The main change from the previous version is the withdrawal of the Bahamas

Key Takeaways On 6 February 2024, the Luxembourg Higher Administrative Court denied the benefits of the Luxembourg participation exemption to participations which had been lent by a Luxembourg-resident capital company to third-parties as “ créances-titres ”. Facts at hand In the case at hand, a

On 29 February 2024, the CSSF published a new Circular 24/854 setting out guidelines for the submission of the SRRC (as defined below) by investment fund managers and investment funds supervised by the CSSF (the “ Circular”). The Circular is supported with a FAQ (list of questions and answers) on