Newsletters & Newsflashes

On the 20 November 2023, the Ministerial Decree of 13 October 2023 setting the date for the renewal of staff delegations for the period 2024 to 2029 was published on the Luxembourg Official Gazette. Any Luxembourg company, regardless of the nature of its activity, which employs at least 15 employees

As from fiscal year 2024, new rules apply to the Luxembourg investment tax credit (“ ITC”) mechanism provided by Article 152 bis of the Luxembourg income tax law (“ LITL”). The mechanism has been revised, and its benefits extended to investments and expenses incurred in the context of digital

On 24 November 2023, draft law No. 8342 transposing directive (EU) 2019/1151 of 20 June 2019 amending directive (EU) 2017/1132 as regards the use of digital tools and processes in company law and amending the amended law of 19 December 2002 on the register of commerce and companies and the

On 3 October 2023, the OECD published the multilateral convention (“ MLC”) to facilitate the implementation of the Pillar Two Subject to Tax Rule (“ STTR”) together with an explanatory statement. The STTR is part of Pillar Two together with the GloBE Rules (i.e., Income Inclusion Rule and Undertaxed

On 20 December 2023, the law (the “ Pillar Two Law”) transposing Council Directive (EU) 2022/2523 of 15 December 2022 (the “ Pillar Two Directive”) has been adopted by the Luxembourg parliament, thus ensuring the Income Inclusion Rule (“ IIR”) and the Qualified Domestic Minimum Top-up Tax (“ QDMTT”)

The new Double Tax Treaty between the Grand Duchy of Luxembourg and the United Kingdom of Great Britain and Northern Ireland for the elimination of double taxation with respect to taxes on income and on capital and the prevention of tax evasion and avoidance (the “ DTT”), and the related protocol

On 22 December 2023, the Luxembourg parliament adopted the law ratifying the Protocol amending the Double Tax Treaty between Luxembourg and Germany (the “ DTT”), as agreed and signed on 6 July 2023 in Berlin (the “ Law”). The requirements for the entry into force of the above-mentioned Protocol

On 23 November 2023, the Luxembourg Higher Administrative Court handed down a decision regarding the tax qualification of an interest free loan (“ IFL”) granted by a parent company to a Luxembourg resident company. In the case at hand, a non-resident parent company granted its subsidiary, a

On 11 October 2023, the OECD released a draft multilateral convention (“ MLC”) in relation to Amount A of Pillar One. The draft reflects the current consensus achieved so far amongst members of the OECD/G20 Inclusive Framework on BEPS (“ IF”). On 18 December 2023, the OECD issued a statement

Background On 22 December 2021, the European Commission released a legislative proposal for a Council Directive (“ Draft Directive” or “ Draft ATAD 3”) laying down rules to prevent the misuse of shell entities for tax purposes and amending Directive 2011/16/EU on administrative cooperation in the

On 17 October 2023, the European Council (the " Council") has updated the list of non-cooperative jurisdictions for tax purposes. Antigua and Barbuda, Belize and Seychelles have been added to the EU list of non-tax cooperatives jurisdictions. The EU List is published as an annex to the conclusions

Directive (EU) 2021/2167 of 24 November 2021 on credit servicers and credit purchasers and amending Directives 2008/48/EC and 2014/17/EU (the “ Directive”) which will regulate the sale, purchase and servicing of non-performing loans originated by EU Banks should have been transposed in all Member