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BSP’s lawyers regularly share their knowledge through regular legal updates, newsletters and professional publications.
Latest Newsletters & Newsflashes
Feb 04, 2025Newsflash | New Luxembourg Circular on interest rates on shareholders’ current accounts
On 29 January 2025, the Luxembourg Tax Authorities (“ LTA”) issued a new Circular LITL No. 164/1 (the “ New Circular”), replacing Circular LIR No. 164/1 dated 23 March 1998 (the “ Previous Circular”) on the interest rates related to current account of associates or shareholders of entities subject
Jan 30, 2025European Court of Justice denies the tax deduction of (arm’s length) interest expenses in the context of a non-genuine arrangement
On 4 October 2024, the European Court of Justice (the “ ECJ”) (Case C-585/22) ruled that Article 49 of the Treaty on the Functioning of the European Union (the “ TFEU”), which guarantees the freedom of establishment, does not preclude national legislation from fully denying the deduction of interest
Oct 23, 2024CbCR I Proposal of common template and electronic reporting formats
On 1 August 2024, the European Commission released a draft regulation to standardize multinational enterprises (“ MNEs”) income tax information for public Country-by-Country Reporting (“ CbCR”), as required by Directive 2013/34/EU. The proposal introduces a common template and electronic formats to
Jul 08, 2024Luxembourg Case Law | Abuse of law in the context of permanent establishments and interest free loans qualification
On 8 May 2024, the Luxembourg Lower Administrative Tribunal (the “ Tribunal”) (n° 47267) ruled on the tax qualification of interest-free loans (“ IFLs”) granted by a parent company to a Luxembourg subsidiary (the “ Company”) as well as the non-existence of a Malaysian permanent establishment (the “
Apr 16, 2024ECON opinion on EC proposal for Transfer Pricing Directive
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
Mar 25, 2024Newsflash | Pillar Two - The Luxembourg Tax Authorities issue a first FAQ
On 25 March 2024, the Luxembourg Tax Authorities (“ LTA”) published their first FAQ regarding the law of 22 December 2023 on the minimum effective taxation transposing Council Directive (EU) 2022/2523 of 15 December 2022 (the “ Pillar Two Law”). For further insights into the Pillar Two Law, please
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