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Significant changes have taken place in the Luxembourg tax landscape in the course of the year 2024, as demonstrated by the intense legislative activity until the last days of 2024, with several measures taking effect as from fiscal year 2025, as summarised below. Corporate taxpayers Corporate

On 28 October 2024, the EU Commission (“ EC”) introduced a proposal to amend Directive 2011/16/EU on administrative cooperation in the field of taxation (“ DAC”) to ease the exchange for Pillar Two information returns within the EU (the “ EC Proposal”). Background On 20 December 2021, the OECD and

On 10 September 2024, the ECJ ruled in favour of the EU Commission in case C-465/20 P, European Commission v Ireland and Apple Sales International relating to State aid granted by Ireland to Apple. Contrary to other State aid decisions involving transfer pricing, the ECJ accepted OECD transfer

On 27 September 2024, the Luxembourg tax authorities issued Circular n° 115/14 clarifying certain aspects of the partially tax-exempt rent subsidy which has been introduced by the law of 22 May 2024 and applicable since 1 st June 2024 ( see our previous newsflash). Background The rent subsidy

On 9 October 2024, Luxembourg’s Finance Minister submitted draft budget law No. 8444 to the Luxembourg Parliament (the “ Draft Budget Law”). The main tax measure is the reduction by fifty percent of the taxable basis for registration and transcription duties applicable to real estate acquisitions

On 19 July 2024, Luxembourg direct tax authorities issued circular L.I.R. n° 170/1, 170bis/1, I.C.C. n° 44, I.Fort. n° 55 (the “ Circular”) clarifying the Luxembourg tax treatment of the dissolution without liquidation under art. 1865 bis of the Civil Code (also called in practice simplified