Luxembourg: Tax Authorities

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Tax law and international tax law thought leadership, articles, podcasts, videos and webinars from expert sources across the legal world. Explore insights covering topics such as capital gains tax, corporate tax, income tax, inheritance tax, national insurance, property taxes, sales taxes, VAT, GST, tax authorities, transfer pricing and withholding tax.

Market Commentary: Crypto Liquidations And Hidden Tax Consequences

The crypto market experienced another resilience test over the weekend, following Donald Trump's remarks on China. As stock markets closed worldwide, volatility shifted to crypto markets.

Luxembourg Technology

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ATOZ

Recommendations On Savings And Investment Accounts

On 30 September 2025, the European Commission published two initiatives to advance the Savings and Investments Union.

European Union Finance

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Loyens & Loeff

EU List Of Non-Cooperative Jurisdictions For Tax Purposes Confirmed By The EU Council

During today's ECOFIN meeting, the EU Council has reaffirmed the EU list of noncooperative jurisdictions for tax purposes ("Blacklist").

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ATOZ

ATOZ Insights - October 2025

On 4 April 2025, the Luxembourg Government approved draft law No. 8526 ("Draft Law"). This legislative proposal aims to introduce a new fiscal incentive, a tax credit specifically designed to encourage individuals...

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ATOZ

US Fund Managers: What To Know About Luxembourg Payroll & Social Security Taxes – New York Office Snippet

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Loyens & Loeff

Pillar Two: Dutch Tax Authorities Publish Q&A

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Loyens & Loeff

Budget Day 2025: Tax Update Automotive Sector

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Loyens & Loeff

Reverse Hybrid Mismatches: Is The CIV Carve-out Finally Decoded?

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A&O Shearman

Transfer Pricing Adjustments Within Multinational Groups May Be Subject To VAT: Milestone Decision By Court Of Justice Of The EU

AM

Arendt & Medernach

Welcome Clarifications On The CIV Exemption For Luxembourg's ATAD 2 Reverse-Hybrid Rules

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Dechert

Revamping The Carried Interest Regime In Luxembourg

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Dechert

Carried Interest: Luxembourg Opportunities | Remuneration Essentials (Video)

Luxembourg Finance

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Arendt & Medernach

Luxembourg Tax Authorities Clarify Reverse Hybrid Rules CIV Exemption Criteria

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Arendt & Medernach

Luxembourg Releases Circular On The CIV Carve-Out From The Reverse Hybrid Mismatch Rule

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ATOZ

AI Strategy: Considerations For Financial Institutions

Luxembourg Technology

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ELVINGER HOSS PRUSSEN, société anonyme

Reverse Hybrid Mismatches: Is The CIV Carve-out Finally Decoded?

AO

A&O Shearman

Your Go-To Guide To Patent Renewals

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Dennemeyer S.A.

Pillar Two: Dutch Tax Authorities Publish Q&A

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Loyens & Loeff

Navigating Luxembourg's Enhanced AML Framework For Funds

Luxembourg Government

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Maples Group

Luxembourg Tax Authorities Clarify CIV Exemption Criteria For Investment Funds

New guidance resolves key uncertainties under ATAD 2 reverse hybrid rules and provides immediate compliance roadmap for fund structures.

AM

Arendt & Medernach

Luxembourg Clarifies The Exclusion For Collective Investment Vehicles - Key Points For Investment Funds

On 22 August 2025, the Luxembourg tax authorities ("LTA") published a new Circular (L.I.R. nº 168quater/2, dated 12 August 2025) addressing certain aspects of the Luxembourg reverse hybrid mismatch rules ("RHMR").

Luxembourg Finance

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CMS Luxembourg

Luxembourg Tax Administration Clarifies CIV Carve-out Under Reverse Hybrid Mismatch Rule

Effective as of fiscal year 2022, a Luxembourg tax transparent entity may, under certain conditions, become subject to Luxembourg corporate income tax if its net income is not taxed as result...

AO

A&O Shearman

Luxembourg Reverse Hybrid Entity Rules: Clarifications Regarding The CIV Exemption

On 22 August 2025, the Luxembourg tax authorities issued a second circular (Circular) on the reverse hybrid entity rules, this time clarifying the exemption applicable to collective investment vehicles (CIV Exemption).

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Herbert Smith Freehills Kramer LLP

ATAD2 CIV Exemption Is Back In The Game!

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ELVINGER HOSS PRUSSEN, société anonyme

Luxembourg Tax Authorities Clarify The "CIV Carve-out" Under The Reverse Hybrid Rules

LL

Loyens & Loeff

Landmark Decision On Qualification Of Financial Instruments & Non-recognition Of A Foreign Permanent Establishment

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BSP

Luxembourg Submits Draft Law Transposing DAC9 And Amending Pillar Two Framework

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ATOZ

Carried Interest 2.0: Luxembourg Modernises Its Tax Treatment For Fund Managers

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Goodwin Procter LLP

Luxembourg Government Releases Draft Law Implementing DAC8

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ATOZ

Luxembourg Carried Interest Taxation: Key Takeaways Of The Proposed New Regime

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ELVINGER HOSS PRUSSEN, société anonyme

Amendments To Draft Law On Property Tax And Tax On Land Mobilisation Submitted To Parliament

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ATOZ

Tax And Legal Considerations Of The New Impatriate Regime

Luxembourg Employment

LL

Loyens & Loeff

European Court Further Clarifies Interplay Between VAT And Transfer Pricing

European Union Tax

LL

Loyens & Loeff

Luxembourg Carried Interest Taxation: Key Takeaways Of The Proposed New Regime

As announced by the Luxembourg Government in its action plan to enhance Luxembourg competitiveness and attractivity, Bill of Law no 8590 was submitted on 24 July 2025...

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ELVINGER HOSS PRUSSEN, société anonyme

Amendments To Draft Law On Property Tax And Tax On Land Mobilisation Submitted To Parliament

On 15 July 2025, the Luxembourg government submitted a series of governmental amendments to draft law n°8082A (the "Draft Law") on property tax (impôt foncier, "IFON")...

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ATOZ

Tax And Legal Considerations Of The New Impatriate Regime

In January 2025, Luxembourg recently modified the impatriate tax regime. Its main objective is to attract qualified foreign profiles.

Luxembourg Employment

LL

Loyens & Loeff

European Court Further Clarifies Interplay Between VAT And Transfer Pricing

In a ruling of 3 July, the European Court offers further clarity on how intra-group transfer pricing arrangements should be treated for VAT.

European Union Tax

LL

Loyens & Loeff

G7 Global Minimum Tax Agreement With The US Announced - Relief For EU Funds And EU-owned MNEs As The US Intend To Drop Withholding Tax Threat

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ATOZ

PART II Fund Regime - Update May 2025

This memorandum gives an overview of the key features of the Part II Funds regime for alternative investment funds accessible to non-professional investors. The impact of the ELTIF Regulation is also highlighted.

Luxembourg Finance

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ELVINGER HOSS PRUSSEN, société anonyme

Funds & Investment Management Update – Ireland And Luxembourg Q1 2025

Directive (EU) 2024/927 amending AIFMD 2011/61/EU and the UCITS Directive 2009/65/EC relating...

European Union Finance

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Maples Group

Enforcing FATCA And CRS Compliance: Luxembourg, Cayman Islands, And BVI Lead The Charge

Since their introduction over 10 years ago, the Foreign Account Tax Compliance Act (FATCA) and the Common Reporting Standard (CRS)...

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Marcum

Corporate Tax In Luxembourg: What You Need To Know

Luxembourg has several forms of entities with separate legal personality. Businesses generally incorporate an entity with limited liability set up in one of the following forms...

European Union Tax

LL

Loyens & Loeff

EU Tax Directives #5: Proposed EU Transfer Pricing Directive – New York Office Snippet

European Union Tax

LL

Loyens & Loeff

Draft Law Introducing A New Start-up Tax Credit For Individuals As From 2026 Released

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ATOZ

Council Adopts DAC9 To Extend Cooperation And Information Exchange Between Tax Authorities To Pillar Two

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ATOZ

Pillar Two: EU Council Adopts DAC9 Proposal

European Union Tax

LL

Loyens & Loeff

Transfer Pricing Adjustments And VAT For Multinational Groups: Latest CJEU Developments

AM

Arendt & Medernach

Luxembourg Accounting Board Issues New Pillar Two Q&A

LL

Loyens & Loeff

Liquidation Loss Allowed Notwithstanding Use Of Irish Group Relief Regime

LL

Loyens & Loeff

EU Proposal To Simplify Pillar 2 Filing Obligations For MNEs Adopted

European Union Tax

AM

Arendt & Medernach

Was Your SIF Set Up Before 2016? Consider A RAIF Conversion While Evaluating The Benefits Of Maintaining A SIF

Luxembourg Finance

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Goodwin Procter LLP

Pillar Two: EU Council Reaches Political Agreement On DAC9 Proposal

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Loyens & Loeff

Luxembourg Replaces Tax Treaty Benefits And UCI Residency Certificates Circular

MG

Maples Group

EU Tax Directives #3: The EU Public CbCR Directive – New York Office Snippet

European Union Tax

LL

Loyens & Loeff

News On Luxembourg Funds

Luxembourg Finance

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Arnone & Sicomo

Tax Update In Luxembourg Regarding Interest Rates For Shareholder Current Accounts

GP

Goodwin Procter LLP

Welcome Clarification On Dutch Transfer Pricing Mismatch Legislation Scope In Respect Of Deemed Dividend Distribution Due To Non-arm's Length Transaction Between Foreign Subsidiaries

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Loyens & Loeff

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Latest Videos

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Carried Interest: Luxembourg Opportunities | Remuneration Essentials (Video)

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Arendt & Medernach

Non Domiciled Tax Status Secrets REVEALED! (Video)

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CYAUSE Audit Services Ltd

SRS Legal Spotlight - Tax | IFICI (Video)

SRS Legal

Portugal Golden Visa Tax Rules: 2024 Update (Video)

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INGWE

Budget Briefing 2025 – What Can Your Business Expect (Video)

BW

Byrne Wallace

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