News & Articles

24/12/21

EU Commission presents proposals for directives against shell entities and ensuring a global minimum level of …

On 22 December 2021 the European Commission (hereinafter: ‘EC’) presented two legislative proposals for EU directives, one to introduce a global minim…

23/12/21

Unshell Directive Proposal: the poisoned Christmas gift of the European Commission

16/12/21

Data protection notices after the Whatsapp case: what's the message?

A few months ago, the Irish Data Protection Commission imposed an administrative fine of EUR 225 million on WhatsApp Ireland Limited, declaring the co…

14/12/21

Countdown to the entry into force of the Luxembourg Reverse Hybrid Rule

The countdown has started. As from 1 January 2022, the last anti-hybrid mismatch provision related to reverse hybrid rule will enter into force. Under…

26/11/21

Prohibition of online advertising in a list of e-mails or messages – a misstep by the CJEU?

When submitted a request for a preliminary ruling, the Court of Justice of the European Union (CJEU) is expect to answer questions – not raise too man…

25/11/21

Impôt minimum mondial : un bref état des lieux des dernières avancées

 L’intégration des économies et des marchés nationaux a connu une accélération marquée ces dernières années, mettant à l’épreuve le cadre fiscal …

27/10/21

New taxonomy-related disclosures RTS published

Despite the delay to Level II1 announced by the European Commission (“EC”) at the beginning of the summer 2021, the last few months have been bus…

26/10/21

Sustainable Finance update (asset management): Final Report on SFDR RTS regarding taxonomy-related disclosures…

On 22 October 2021, the European Supervisory Authorities or ESAs (EBA, EIOPA and ESMA)  presented the European Commission with their Final Report…

22/10/21

The new EU toolbox to tackle soaring energy prices

The ongoing energy price crisis in the aftermath of COVID-19, which has curtailed industrial production and left consumers across Europe facing higher…

22/10/21

Comparability of Investment Funds – another Finnish referral to the Court of Justice of the European Union – a…

Recently, an Advocate General’s opinion (the “Opinion”) on Finnish CJEU case C-342/20 (the “Case”) has been published.

12/10/21

Agreement on Pillar One and Pillar Two global tax reform

On 8 October 2021, 136 out of 140 members of the OECD/G20 Inclusive Framework officially agreed on certain key parameters to reallocate some taxing ri…

24/09/21

The Arm’s Length Principle And Profit Participating Loans: First Decision By Luxembourg Courts - Tax Case Stud…

Our tax litigation team recently had the opportunity to assist a taxpayer in an appeal for the reversal of a decision issued by the Luxembourg tax adm…

17/09/21

Property companies holding real estate assets in Germany – state of play on the input VAT deduction right

The case concerned a Jersey-based company, Titanium Ltd (‘Titanium’), involved in real estate and asset management activities.

14/09/21

Direct taxation - AG Kokott opines on the ‘expected interest’-criterium (État luxembourgeois)

The French tax authorities made a request for exchange of information to the Luxembourg tax authorities aiming at the bene cial owners of the Lux…

10/09/21

Clarification on losses carry forward and social security deductions

On 10 August 2021, the Luxembourg Tax Authorities issued a new circular I.C.C n° 31 clarifying the application of carried forward tax losses and the d…

08/09/21

VAT deduction right of Lux PropCos owning/exploiting German real estate – VAT changes

In its decision C-931/19 (“Titanium case”), the Court of Justice of the European Union (“CJEU”) ruled that a foreign company should not be considered …

02/09/21

The CJEU extends Achmea to intra-EU Energy Charter Treaty arbitrations

In a judgment dated 2 September 2021 in Komstroy v Moldova (Case C-741/19), the Court of Justice of the European Union (“CJEU”) has hel…

02/08/21

Taxation of the Digital economy: What’s in the pipeline?

At the end of 2020, the OECD aimed at addressing and coming to a successful conclusion on tax challenges arising from globalisation and the digitalisa…

19/07/21

Draft revised vertical regulation and guidelines

The European Commission takes a hard line against online platforms, dual distribution and MFNs

13/07/21

General Court of the CJ annuls State aid decision in Amazon case

The case concerned the arm’s length nature of a royalty paid by a Luxembourg operating company (LuxOpCo) to a Luxembourg partnership (LuxSCS) – a…