Luxembourg Tax News
Treaty between Luxembourg and Cyprus initialled
Tax plan 2008 – corporate income tax (details)
Treaty between Luxembourg and Hong Kong signed and details
ECJ: hearing in case regarding transitional rules in respect of abolished German imputation system
Phased abolition of capital duty announced
Protocol to treaty between Luxembourg and France ratified
ECJ: Advocate General finds Swedish legislation limiting the exemption of third-country dividends justifiable restriction on EC free movement of capital – details
Compatibility of exclusion of indirect ownership through companies in other EU Member States for French tax consolidation purposes with freedom of establishment referred to ECJ
OECD releases revised draft of Part IV (Insurance) of the Report on Attribution of Profits to Permanent Establishments
Treaty between Luxembourg and Hong Kong initialled
ECJ: Finnish group contribution regime compatible with EC Law – details
Treaty between Canada and Luxembourg – Canadian Federal Court of Appeal upholds Tax Court decision on non-applicability of general anti-avoidance rule to sale of shares
ECJ: Interprets anti-avoidance clause under the Merger Directive with respect to Danish rules on taxation of exchanges of shares – details
EU Commission refers Greece to ECJ concerning discriminatory taxation of dividends
Second Guideline on implications of ECJ Denkavit case on French dividend withholding tax published
EU Commission progresses infringement procedure against Austria, Germany, Italy and Finland regarding taxation of outbound dividends
ECJ: Swedish legislation on dividend tax relief in relations with third countries is compatible with EC law – details
ECJ: Advocate General holds German switch-over provision for low-taxed passive income of foreign PEs incompatible with EC Law – details
ECJ: Advocate General finds Dutch withholding tax on outbound dividends incompatible with EC free movement of capital – details
ECJ: Previous Austrian rules discriminating dividends received from third countries are compatible with free movement of capital under grandfathering clause – details
ECJ: German thin capitalization rules reclassifying interests paid to substantial shareholders in third States are not incompatible with EC law
Treaty between Luxembourg and France – Luxembourg Administrative Court rules income of Luxembourg SA from French real estate owned by French SCI taxable in Luxembourg
Treaty between Belgium and Luxembourg – Luxembourg Administrative Court of Appeal decides denial of group tax treatment compatible with non-discrimination provision
Discussion draft on application and interpretation of non-discrimination article of OECD Model – details
International tax conference on CCCTB held in Berlin
Bill to implement various EU Directives submitted to Luxembourg parliament
Revised Commentary on Article 7 of OECD Model released
New specialized investment fund regime introduced
ECJ: temporal effects of judgment in Meilicke against Germany should not be limited – details
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