On 13 December 2017, the Luxembourg Council of Ministers approved an amendment to the draft legislation currently before parliament for the introduction of a new IP regime ({News-2017-08-14/P/2-previous coverage}). The amendment provides for additional requirements with respect to qualifying R&D expenditure for a taxpayer when incurred by a foreign branch (PE) in an EU/EEA Member State. The additional requirements include that the expenses must be directly related to the manufacturing, de…