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Luxembourg: Interest deduction limitation rule – New guidance released by the Luxembourg tax authorities

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In brief On 8 January 2021, the Luxembourg tax authorities released Circular L.I.R. No. 168bis/1 ("Circular") providing guidance on the application of the interest deduction...

Luxembourg: Law on the denial of deductibility of interest and royalty payments made to...

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On 28 January 2021, the Luxembourg Parliament (Chambre des Députés) adopted1 bill of law 7547 on the non-deductibility of interest and royalty payments made to related parties in non-cooperative jurisdictions (“Law”).As explained in our tax alert dated 20 April 2020, the new provision amends Article 168 of the Luxembourg Income Tax Law (LITL), which lists non-deductible expenses for taxpayers subject to corporate income tax. The Law therefore completes the scope of non-deductible expenses by adding a rule of non-deductibility of interest or royalty expenses paid by a Luxembourg taxpayer to a related company established in a country or territory appearing on the list of the EU as a non-cooperative tax jurisdiction.

Europe: Brexit and GDPR

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In brief On 31 December 2020, the National Commission for Data Protection (CNPD) published a statement on the applicability of Regulation (EU) 2016/679 of the European Parliament...

Europe: Post-COVID-19 Cross-border remote working: managing tax risks

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The pandemic has impacted our lives in many ways, but for many of us, one of the most affected areas has certainly been work.COVID-19...

Luxembourg: Incentive scheme for hiring highly skilled employees – an update of the regime

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On 14 October 2020, Luxembourg announced new provisions with respect to incentive for highly skilled and qualified workers ("Impatriate Regime") as part of the 2021 budget bill ("Law").1The Impatriate Regime was introduced back in 20112 and was further amended by several circulars, including the most recent Circular LIR No. 95/2 dated 27 January 2014 ("Circular") which have been repealed in the meantime. The government has now decided to codify the Impatriate Regime under Article 115(13) b. of the Luxembourg income tax law (LITL) and to introduce some limited changes.The aim of Article 115(13) b. of the LITL remains close to the original objective of the Circular, which was to further enhance the competitiveness of Luxembourg by enabling Luxembourg employers to hire new talent from abroad. The changes introduced by the Law should further simplify the procedure, strengthening the clear intention of Luxembourg to remain attractive from an economic perspective.Below we describe the regime that will be applicable as from 1 January 2021 while highlighting the main changes compared to the former rules.

Poland: Obligation to report all contracts for the performance of a specific task

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Stay up to date with all the latest news and publications on employment law in Poland and the potential impact it may have.

Luxembourg: From ESG Compliance to Impact Investing: The Extra Mile of the Real Estate...

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The fund industry has absorbed many regulatory reforms in a decade, most notably with the AIFMD first and the increased level of risk management,...

Luxembourg: Mandatory disclosure rules (DAC6) – A look at private equity investment in Luxembourg

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On May 25 2018, the Council of the European Union adopted a directive concerning the mandatory automatic exchange of information in the field of taxation, in relation to reportable cross-border arrangements (Council Directive (EU) 2018/822).  This EU mandatory disclosure regime, known as the DAC6 Directive, aims to increase transparency by requiring intermediaries and, in certain circumstances, taxpayers, to report cross-border transactions that are deemed to represent aggressive tax planning.

Luxembourg: Mandatory disclosure rules (DAC6)

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On 25 May 2018, the Council of the European Union adopted a directive concerning the mandatory automatic exchange of information in the field of...

Luxembourg: Main tax measures of the 2021 draft budget law announced during State of...

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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...
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