On 8 January 2021, the Luxembourg direct tax authorities issued the Circular n°168bis/1 which clarifies the provisions of article 168 bis of the Luxembourg income tax law on the Luxembourg interest deduction limitation rule.
On 8 January 2021, the Luxembourg tax authorities issued a new Circular n° 168bis/1 (the “Circular”) in order to provide guidance on the interpretation of the interest deduction limitation rules (“IDLR”) laid down in Article 168bis of the Luxembourg income tax law (“LITL”).
On 23 December 2020, the Luxembourg Budget Law was published in the MeÌmorial (“the Law”). It contains some tax measures aiming at promoting investment in sustainable economic activities and is part of a more extensive sustainable finance strategy for Luxembourg as an international financial centre.
On 18 December 2020, the OECD published its much-anticipated “Guidance on the Transfer Pricing Implications of the COVID-19 Pandemic”.
On 14 October 2020, the Luxembourg government submitted to the Parliament the budget bill for fiscal year 2021. It was approved by the Parliament on 17 December 2020 and published in the Official Journal on 23 December 2020 (the Law).
On 15 December 2020, the Luxembourg Parliament approved the 2021 budget bill.
llowing the European Court of Justice (ECJ) ruling of 2 April 2020 in case C-458-181, the Luxembourg direct tax authorities issued a circular letter (Circular) on 1 December 20202 regarding the non-application of Council Directive 2011/96/EU of 30 November 2011
List of double tax treaties in force and in negotiation as of 23 November 2020.
A draft law adopted by the Luxembourg Government in March 2020, which should be passed soon, will introduce a new Luxembourg tax measure denying under certain conditions the corporate income tax deduction of interest and royalty expenses directed at entities located in non-cooperative tax jurisdictions.
On 1 December 2020, the Luxembourg tax authorities issued Circular L.I.R. n°147/2, 166/2 and Eval. N°63 (“Circular”) related to the application of the EU Parent Subsidiary Directive (“PSD”) to companies incorporated in Gibraltar.
