Within the EU a widespread asymmetry exists between debt and equity financing. Usually, interest is tax deductible from the corporate income tax base while dividends do not benefit from such advantage
The EU Commission published its already much-debated DEBRA proposal on 11th May 2022, in her move to re-vamp again the tax environment in which corporate taxpayers try to navigate
On 11 May 2022, the EU Commission issued a draft directive proposing a debt-equity bias reduction allowance (the “DEBRA Proposal”). The DEBRA Proposal lays down rules (i) to provide, under certain conditions,
On 11 May 2022, the European Commission published a Directive proposal to tackle the tax bias in favour of debt funding. The proposal includes both a notional deduction on growth in equity
On 20 January 2022, the Luxembourg tax authorities (the LTA) published the circular PRE_IMM n°1 (the Circular) which clarifies the provision related to the new real estate tax (RET) introduced by the 2021 budget law.
On 31 March 2022, the Luxembourg Administrative Court ruled that account 115 contributions are not to be taken into account to determine the minimum acquisition value of a participation for the purposes of the Luxembourg parent-subsidiary exemption.
On 9 March 2022, a draft law was presented to Parliament in order to remove the exemption applicable to securitisation entities within the meaning of EU Regulation 2017/2402 of 12 December 2017 (the “EU Securitisation Regulation”) from the interest limitation rules
On 9 March 2022, a bill amending Article 168bis of the Luxembourg Income Tax Act was brought before Parliament. The bill aims to remove 2017 securitisation entities from the list of financial undertakings
On 9th March 2022, the Luxembourg Ministry of Finance introduced a new bill of law n°7974 before the Luxembourg Parliament, which amends the current interest deduction limitation rule (“IDLR”) by removing EU regulated securitization vehicles (“SVs”) from the exemption provided for financial undertakings.
The Luxembourg tax authorities (“LTA”) released a new circular on 20 January 2022 (PRE_IMM n°1) (the “Circular”) regarding the real estate levy previously introduced by the Luxembourg law of 19 December 2020 (the “Law”).
