Luxembourg Tax News

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Treaty between India and Luxembourg signed

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European Commission takes steps against Bulgaria, Portugal, Romania and Spain concerning taxation of dividends

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Draft of 2008 Model Tax Convention – Proposed changes to Commentary to Art. 12 (definition of royalties)

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Reduction of corporate income tax and abolition of capital duty announced

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ECJ: Decision by reasoned order in UK CFC and foreign dividend test case

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European Commission closes infringement procedure against Luxembourg concerning taxation of dividends

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ECJ: Advocate General finds Belgian rules on inclusion of dividends in taxable base followed by 95% deduction insofar as parent company makes profits incompatible with Parent-Subsidiary Directive – details

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Treaty between Belgium and Luxembourg – Belgian ruling that income from real estate certificates classified as interest

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ECJ: Non-deductibility of foreign PE losses in Germany compatible with EC freedom of establishment

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ECJ: Netherlands refund regime for investment funds incompatible with EC free movement of capital

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European Commission refers Netherlands to ECJ for not exempting dividends paid to companies established in certain EFTA countries from withholding tax

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Treaty between Luxembourg and Hong Kong submitted to Luxembourg parliament

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ECJ: 5% add-back of tax credits for withholding tax at source abroad compatible with Parent-Subsidiary Directive

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European Commission takes steps against Germany, Estonia and Czech Republic regarding taxation of outbound dividends

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European Commission takes steps against Belgium for failure to adopt implementing measures of Merger Directive

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Treaty between Hong Kong and Luxembourg – gazetted by Hong Kong

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ECJ: Advocate General finds German rules on taxation of cross-border dividends under old imputation system compatible with EC law

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Indian Cabinet approves tax treaty with Luxembourg

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ECJ: Advocate General finds 5% add-back of tax credits for withholding tax abroad compatible with Parent-Subsidiary Directive – details

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OECD released discussion draft on transactional profit methods

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ECJ: Advocate General finds the 5% add-back of tax credits for withholding tax at source abroad compatible with Parent-Subsidiary Directive

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European Commission issues communication regarding accession of Bulgaria and Romania to Arbitration Convention

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Protocol to treaty between Luxembourg and France enters into force

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ECJ: Swedish legislation limiting exemption of third-country dividends justifiable restriction on EC free movement of capital – details

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Bill to implement various EU Directives adopted by Luxembourg parliament

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ECJ:Swedish legislation limiting exemption of third-country dividends justifiable restriction on EC free movement of capital

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Communication published on application of anti-abuse measures in area of direct taxation – within the EU and in relation to third countries

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ECJ: German transitional rules for taxation of capital gains incompatible with EC free movement of capital

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Protocol to treaty between Luxembourg and France ratified

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Treaty between Qatar and Luxembourg initialled

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