Introduced Tax Changes in Luxembourg

Amendments to the participation exemption regime, the tax consolidation regime, the net wealth tax rules and to the minimum tax rules are only a few of the numerous tax changes introduced. There are also changes to be introduced by tax treaties recently ratified by Luxembourg and their ratification status in other countries along with the dates of application. In 2016, with CRS becoming the new standard, Luxembourg is taking a big step in exchange of information in tax matters. This year, we will also see the birth of a new type of Luxembourg alternative investment fund called “reserved alternative investment fund” which will offer authorised AIFMs the opportunity to launch funds with the same benefits as specialised investment funds, but without prior supervisory approval, reducing “time to market”.

At EU level, the Directive on exchange of information on tax rulings has now been published and will have to be implemented by Luxembourg before the year-end. As far as BEPS is concerned, the European Union is demonstrating its willingness to act quickly, and released on 28 January a so-called anti-tax avoidance package, including a draft anti-BEPS directive, which aims to tackle many of the BEPS issues identified by the OECD (although this Directive will not specifically deal with VAT – it will have certain VAT ‘effects’. On VAT matters, a recent positive ECJ decision confirmed that the management of regulated real estate funds may benefit from a VAT exemption. The ECJ decision also provides some useful information to determine which types of management services which are covered/not covered by the VAT exemption.

Internationally, BEPS continues to dominate the international tax agenda with the recent signature by 31 countries, including Luxembourg, of a tax co-operation agreement to enable automatic sharing of country-by-country information.


Jeremie Schaeffer and Suzana Guzu Mercea
ATOZ Tax Advisers

Join incoming Conference

Linked In

News from the Board

IVA Meeting with HMRC

The meeting, which took place in London in February, was very much a follow-up and review of the progress made since the previous meetings in relation to in particular but not exclusively on the certificates of status required by the UK authorities in the context of 13th Directive (non-EU) claims...

Read more ...

News from IVA members

Setting up agents’ accounts for MTD – UK

A number of members have indicated that they are having problems setting up agents’ accounts to be able to file UK VAT returns via the new MTD process...

Read more ...

News from EC

News from Accountancy Europe - May 2019

The European Commission has proposed to exempt supplies to armed forces from VAT and excise duties when these forces are deployed outside their own Member State and take part in a European defense effort under the Common Security and Defense Policy (CSDP).

Read more ...

Disclaimer:  The information contained in the present page is general and does not constitute legal advice. Before taking any decision or action on the above information you should take the appropriate professional advice.