The double tax treaty signed by Luxembourg and Cyprus entered into force on 21 May 2018 its provisions will apply as of 1 January 2019. This double tax treaty takes into account the latest international standards regarding avoidance of double non-taxation and exchange of information, such as the Erosion and Profit Shifting (BEPS) recommendations of […]
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 […]
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) […]
The Law and the Grand-Ducal Regulation of 30 may 2018 transposing the revised EU markets in financial instruments directive (MiFID II) into Luxembourg law were published in the Official Journal. As a reminder, MiFID came into effect on 3 January 2018. It aims at strengthening regulation of trading activities on financial markets and at enhancing […]
The Law of 27 February 2018 on interchange fees and amending several laws relating to financial services was published on 1 March 2018. It modifies, among other things, the rules governing professional secrecy laid down by article 41 of the Law of 5 April 1993 on the financial sector. As a reminder, the professional secrecy […]
The Law of 27 February 2018 (“the 2018 Law”) came into force on 5 March 2018. Besides implementing (EU) Regulation 2015/751 on interchange fees for card-based payment transactions, the 2018 Law amends the Law of 17 December 2010 on undertakings for collective investment (“UCI Law”). One of the goals of the 2018 Law is to […]
Directive of 30 May 2018 on the prevention of the use of the financial system for the purposes of money laundering or terrorist financing (the “Fifth AML Directive”) was published in the Official Journal of the European Union. EU Member States now have 18 months to implement the Fifth AML Directive into national law (10 […]
On 14 March 2018, the CSSF issued two warning statements on (i) initial coin offerings (ICOs) and tokens and on (ii) virtual currencies (also called cryptocurrencies). The CSSF acknowledges that the blockchain technology underlying ICOs and virtual currencies may bring about certain benefits when used in the financial sector and in various innovative projects. However, […]
Please view our new legal watch (Link HERE) The Legal watch includes the topics below: – Capital Markets – Banking and Finance – Asset Management and Investment Funds – Tax – Data Protection
Please view our new legal watch (Link HERE) The Legal watch includes the topics below: – Capital Markets – Banking and Finance – Asset Management and Investment Funds – Tax – Data Protection
Luxembourg recently introduced into domestic tax law the basic transfer pricing principles foreseen by Articles 8 -10 of the OECD BEPS report. Luxembourg will have to implement the anti-tax avoidance directive which includes the principles set out by the OECD BEPS report as regards hybrid mismatch (Action 2), CFC Rules (Action 3), Limitation of Interest […]
Several Luxembourg-based banks have refused to accept US clients to avoid FATCA-related reporting. However, as one of the major financial centres in the world, Luxembourg’s financial industry has integrated the FATCA consequences in its business model. One of our major challenge in this context is to demonstrate how tax compliance advice can be valuable.