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Corporate tax


Upcoming German tax law changes relevant to real estate investments

Upcoming German tax law changes relevant to real estate investments
18/09/2018

On 1 August 2018, the German Ministry of Finance published the amended draft bill of the Annual Tax Act 2018 which will be subject to further discussions in the parliament in the coming months.

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Luxembourg has started the MLI ratification procedure

Luxembourg has started the MLI ratification procedure
10/09/2018

On 7 June 2017 Luxembourg and more than 70 other jurisdictions signed the multilateral instrument (“MLI”) to integrate base erosion and profit shifting (“BEPS”) measures into double tax treaties.

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Draft Law for the ATAD 1 Implementation

Draft Law for the ATAD 1 Implementation
13/08/2018

On June 18th 2018, the Luxembourg government published a draft law implementing the first Anti-Tax Avoidance Directive (hereafter “ATAD”) into Luxembourg law (please see our Newsletter of April 2016 on the topic of the ATAD).

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New reporting requirements on transactions with related parties

New reporting requirements on transactions with related parties
02/08/2018

On 7 May 2018, the Luxembourg tax authorities released a circular introducing for Luxembourg corporate taxpayers some new reporting requirements on transactions concluded with related parties located in so-called “non-cooperative jurisdictions”.

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The OECD releases the Base Erosion and Profit Shifting (BEPS) public discussion draft on BEPS actions 8-10: Financial Transactions

The OECD releases the Base Erosion and Profit Shifting (BEPS) public discussion draft on BEPS actions 8-10: Financial Transactions
20/07/2018

On 3 July 2018, the OECD launched a consultation on the transfer pricing of financial transactions by publishing the first draft of a new chapter of the OECD Transfer Pricing Guidelines for Tax Administrations and Multinational Enterprises. The consultation comments are invited until the end of the consultation period on 7 September 2018.

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Luxembourg Implementation of Anti-Tax Avoidance Directive

Luxembourg Implementation of Anti-Tax Avoidance Directive
04/07/2018

On 20 June 2018, the Luxembourg Government filed the bill of law n°7318 (“Draft Law”) implementing the so-called Anti-Tax Avoidance Directive (“ATAD 1”).

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Transfer pricing: new requirements in 2017 tax returns

Transfer pricing: new requirements in 2017 tax returns
03/07/2018

The Luxembourg Tax Authorities (“LTA”) inserted in Form 500 “Corporate income tax, municipal business and net worth tax return for resident corporations” for the tax return 2017 the following new disclosure requirements:

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The Luxembourg ATAD bill of law has been published

The Luxembourg ATAD bill of law has been published
29/06/2018

Council Directive (EU) 2016/1164, the “Anti Tax Avoidance Directive” or «ATAD 1 » published on 12 July 2016, implements the OECD’s recommendations set out in the Base Erosion and Profit Shifting (“BEPS”). 

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Fidelity Funds vs the Danish Ministry – CJEU rules in favour of taxpayers

Fidelity Funds vs the Danish Ministry – CJEU rules in favour of taxpayers
26/06/2018

Yesterday (21 June 2018), the European Court ruled in favour of a Fidelity investment fund that had suffered Danish withholding tax at a higher rate than a comparable Danish investment fund. 

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 Luxembourg implements the Anti-Tax Avoidance Directive (ATAD)

Luxembourg implements the Anti-Tax Avoidance Directive (ATAD)
21/06/2018

Today (20.06), the draft law implementing the EU Anti-Tax Avoidance Directive (“ATAD”) was released. While the main purpose of the draft law is to implement ATAD, it is worth noting that it also includes two additional BEPS-related tax changes aiming at removing potential double non-taxation situations.

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