Brexit and asset management: the Luxembourg transfer pricing perspective

The asset management industry in the United Kingdom is the one of the biggest in the world, while Luxembourg is often cited as a key jurisdiction for asset management too, being the largest fund domicile in the EU. At present, although the Brexit negotiations between the UK and EU seem to be at a standstill, many leading asset management firms are planning fo […]

In 2019, what incentives are there for greener transport in Luxembourg?

As of 2019, specific tax allowances have been set up by the government for hybrid company cars in Luxembourg (on top of allowances relating to fully electric cars). Since last year, such cars have been taxed according to how environmentally friendly they are, instead of according to a flat rate. The government’s aim is to incentivize companies to buy eco-frien […]

New court decision shows importance of updated transfer pricing documentation

In a recent court case[1] about transfer pricing for interest rates on intra-group loans, the court ruled in favor of the Luxembourg Tax Authorities (LTA). The LTA had challenged the 12% interest rate payouts of the Luxembourg company (LuxCo), which were considered to deviate from the arm’s length principle. The excessive interest was requalified as hidden div […]

New, ethical Luxembourg–Senegal double tax treaty means opportunity

On 10 February 2016, Luxembourg and Senegal reinforced their co-operation on an international level by signing a double tax treaty. Entering into force on 14 June 2018, and applicable from 1 January 2019, the treaty differs greatly to previous treaties between Luxembourg and African countries in that it is the first one to include specific guidance and provision […]

Luxembourg’s taxation of virtual currencies is competitive in EU

On 26 July 2018, the Luxembourgish Tax Authorities (ACD) published a circular that seeks to clarify the tax treatment of virtual currencies, particularly in the context of disposals and mining. The ACD has taken the stance, currently a mainstream one, that virtual currencies are not considered official currency: under the current paradigm, money is money only […]

Common questions about the impatriate tax regime, answered

In 2014, a tax circular[1] became effective in Luxembourg, aiming to attract skilled employees to the country. It did so by stating that certain expatriation costs usually borne by the hiring company are no longer considered taxable income for the impatriate (if certain conditions relating to the impatriate, the Luxembourg employer, and the position are met). Am […]