FIDUCIARY
LUXEMBOURG - PARIS - GENÈVE
Luxembourg’s tax authorities clarified the tax implications of simplified liquidations, treating them like mergers for tax purposes. The new rules allow tax-neutral treatment under certain conditions and preserve Net Wealth Tax (NWT) reserves. These changes benefit sole shareholders who are looking for efficient business closures.
A Luxembourg SOPARFI is a fully taxable holding company that benefits from tax exemptions on qualifying dividends, capital gains, and certain intellectual property income. It is subject to corporate income tax, municipal business tax, and net wealth tax and may benefit from international tax treaties and European Directives.
Luxembourg's wealth management companies (SPFs) are exempt from corporate income tax, municipal business tax, and net wealth tax, paying a 0.25% subscription tax on share capital and certain debts. SPFs can only hold passive financial assets and are prohibited from engaging in commercial activities or managing subsidiaries.
Luxembourg’s updated inpatriates regime targets international talent by offering a flat 50% income tax exemption on salaries up to EUR 400,000 of impatriates remuneration. This ensures genuine expat recruitment, enhancing the country’s competitiveness.
This article clarifies the differences between the tax forms 200 and 300 in Luxembourg for transparent entities, in particular their taxable income categories and the situations in which they are or are not subject to municipal business tax (MBT).
Due to the heterogeneity of the sources of Luxembourg tax law, tax litigation falls under two branches of the Luxembourg jurisdiction: administrative courts and judicial courts. Direct taxes fall under the jurisdiction or administrative courts, judicial courts have exclusive jurisdiction over ...
Tax losses incurred by a company during a tax year can be carried forward and, in principle, offset against taxable profits in subsequent years, thereby reducing the amount of tax payable. There are, however, restrictions on carry-forward and set-off. Tax losses incurred prior to 31st ...
Owning real estate is more or less tax-efficient depending on the investment objective.
This transfer would therefore no longer result in immediate taxation of deferred profits and unrealised capital gains.
A tax integration regime is nothing more and nothing less than a tax consolidation of a group or part of a group of companies.
The corporate director must be diligent and prudent, they must respect the obligations of its various missions.
The "DAC 6" Act (1) requires taxpayers and certain intermediaries to declare to the tax authorities any cross-border arrangements which are considered to be fiscally aggressive.It should be made clear from the outset that the three criteria listed must be met cumulatively in order for the whole ...
Expertise
Précis de droit comptable et aspects fiscaux
April 2023, publication of the new edition of the Précis de Droit Comptable, by Denis Colin, manager of the Fiduciaire LPG