Luxembourg was one of the leading EU regions for GDP per capita in 2022, at 257% of the EU average: https://bit.ly/3TcLXZP Most EU regions recorded an increase in real GDP in 2022 (231 out of 242 regions). The Bonn & Schmitt team have been involved in many of the major transactions across Luxembourg over the […]
Author: Stéphane Ebel
Bonn & Schmitt’s practice involves trademark and copyright infringement litigation, as well as trade secret and unfair competition litigation. The firm is also a member of APSI (Association of Professionals of the Information Society) and of the AIPPI (Association Internationale pour la protection de la Propriété Intellectuelle). For further information, please visit: https://lnkd.in/enhc4Hp3
The Luxembourg budget for 2023 (the “Budget”) has been adopted by the Luxembourg Parliament on 15 December 2022. While it contains no major tax reforms, there are various tax clarifications and reductions. These are as follows. Clarification on reverse hybrid rules The so-called “reverse hybrid rules” were implemented in Luxembourg domestic law under Article 168quater […]
European Commission vs. FIAT Group: a consistent and satisfactory decision
On November 8, 2022, in joint cases 885/19 and 898/19 (appeal against the judgment of the General Court of the European Union – the “General Court” of September 24, 2019, Luxembourg and Fiat Chrysler Finance Europe v. Commission, Cases T-755/15 and T-759/15) the Court of Justice of the European Union (“CJEU”) annulled the decision of […]
Extended delays to hold annual general meeting and file annual accounts
By a new law adopted on May 22, 2020 and published on May 29, 2020 (hereinafter the “Law”), the Luxembourg parliament decided to extend for three months the deadline for filing / publishing annual accounts, consolidated accounts and that reports relating thereto and the sanctions relating thereto with regard to directors / managers, as referred […]
Asset management & investment funds – Consultation paper on the Regulation on cross-border distribution of funds published by ESMA – Luxembourg regulatory measures in the context of COVID-19 Banking , finance & corporate – Measures related to the holding of corporate meetings in the context of COVID-19 – Anti-money laundering: AML 5 Law Tax – […]
The Law of 17 April 2018 adopted by the Luxembourg Parliament lays down a new intellectual property (“IP”) tax regime effective as of the 2018 tax year. As was the case under the previous regime, the new regime provides for an 80% exemption from corporate income tax on the net income derived from eligible IP […]
Luxembourg bill of law to implement Anti-Tax Avoidance Directive
On 20 June 2018, the Luxembourg Government filed bill of law 7318 implementing Directive (EU) 2016/1164 (the “Anti-Tax Avoidance Directive” or “ATAD I”). The bill of law lays down rules against tax avoidance in the following fields: (i) the limitation on interest deductibility, (ii) exit taxation, (iii) general anti-abuse provisions, (iv) controlled foreign company (CFC) rules and (v) […]
On 20 March 2018, a new double tax treaty and an associated protocol (“New DTT”) were signed by the French and Luxembourg governments. The New DTT will replace the current double tax treaty (dated 1 April 1958) and it will enter into force at the earliest on 1 January 2019, after the completion of the […]
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The Grand-Duchy of Luxembourg is the largest centre for private wealth management in the European Union. One hundred and forty two international banks have been established within its borders, and numerous investment funds are domiciled in the country. As a consequence, Luxembourg has a strong network of double tax treaties developed over several years. As […]
Local financial institutions are well prepared to provide the Luxembourg tax authorities with CRS reporting information. Clients are slowly integrating the new business parameters, such as actual substance requirements, and have closed treaty shopping mechanisms. They have to accept this new ‘tax way of life’. From a practical perspective, clients who remain tax compliant in […]