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In brief Luxembourg Prime Minister, Mr. Bettel, announced on 13 October 2020 some new tax measures during the state of the nation speech. You may recall that a structural tax reform to take place in 2021 was announced by the Minister of Finance, Mr. Gramegna, in July 2019. The Covid-19 outbreak has…

On 14 May 2020, the European Court of Justice (ECJ) issued its decision on case (C-749/18) further to a request for a preliminary ruling by the Luxembourg Administrative Court on 30 November 2018. The ECJ ruled that the strict distinction made by the Luxembourg tax authorities between the vertical and horizontal tax unity regime is contrary to the freedom of establishment set forth in articles 49 and 54 of the Treaty on the Functioning of the European Union (TFEU).

As a result, an EU non-integrating parent entity (i.e., share capital company or permanent establishment) should be able to combine horizontal and vertical tax unity without terminating the pre-existing fiscal unity nor triggering any negative tax consequences resulting from such a termination. Indeed, under Luxembourg current tax consolidation rule, the end of tax unity group before the end of the five years minimum period entails a retroactive tax assessment of each entity on a stand-alone basis.

Countries around the globe are facing unprecedented and rapid change due to the COVID-19 pandemic. The Government Intervention Schemes Guide provides a summary of key government intervention measures across jurisdictions around the globe in relation to: Foreign Investment Restrictions Debt Equity Taxation EU State Aid Approvals (where relevant) Read report…

Baker McKenzie’s EMEA Employment and Compensation Team is pleased to provide you with this quick guide for employers, dealing with 11 of the most pressing issues employers are currently faced in light of the Coronavirus outbreak across 19 European jurisdictions. In the words of our French colleagues: “Pas de Panique”…