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Luxembourg in International Tax Planning by Philip J. Warner Pdf
Study, divided into five parts: a short introduction to Luxembourg as a country and financial centre; calculation of profits taxes and other taxes to which a fully-taxable resident business is subject; the fully-taxable "special purposes vehicles" available in Luxembourg including banking and reinsurance; tax exempt vehicles, the 1929 holding company and investment funds; and corporate reorganizations and examples of how Luxembourg could be used in international tax planning
Luxembourg in International Tax by Marc Schmitz,Philip J. Warner Pdf
Luxembourg in International Tax' takes an in-depth look at corporate taxation in Luxembourg and the tax issues that may be of interest in an international environment. Although it principally focuses on those areas of interest to international investors and tax experts requiring a clear explanation of corporate tax in Luxembourg, it is also of interest to locally based practitioners. The first edition rapidly became a standard reference work in Luxembourg tax literature, and its reputation was maintained through the second edition, which continued being referred to and selling long after the date of issue. 0This new edition of the book is updated to incorporate tax developments on the national level up to January 2015, including the latest changes on the exchange of information, advance tax clearances and the codification of the arm’s length standard. It also covers Luxembourg’s intellectual property box regime, private wealth management companies and other investment entities, and the taxation of financing activities in Luxembourg. Furthermore, it contains a new chapter on tax treaties, which provides insight into the particularities of Luxembourg’s treaty network and its interaction with domestic law. 0The book provides a vast amount of up-to-date information combined with an in-depth analysis of business taxation in Luxembourg. It is a valuable guide for international tax experts wishing to gain a better understanding of corporate tax in Luxembourg as well as for locally based practitioners. With numerous examples given in each chapter, it will also be of interest to students.
International Taxation and Luxembourg’s Economy by Ruud A. de Mooij,Dinar Prihardini,Antje Pflugbeil,Mr.Emil Stavrev Pdf
Luxembourg receives ample investment from multinational corporations, in part due to some attractive features in its international tax rules. Around 95 percent of these foreign investments pass through Luxembourg via companies performing holding and/or intra-group financing activities. While their contribution to Luxembourg’s economy is modest relative to their large overall balance sheets, they still generate around 3 percent of GDP in tax revenue, create almost 4500 direct jobs, and spend almost 3 percent of GDP on salaries and purchases of business services. Ongoing changes in the international corporate tax framework pose risks to these economic contributions, which this paper attempts to quantify. It also discusses options for reforms in Luxembourg’s tax system that could help offset adverse revenue and economic effects.
Guide to the Luxembourg Corporate Tax Return by Maude Bologne,Olivier Buscheman,Grégory Marchal Pdf
Over the past several years, there has been a steady increase in the number of resident taxpayers subject to the various taxes on income and net worth in Luxembourg. However, until now, no complete and up-to-date documentation has been available to guide taxpayers in the preparation of their tax returns. This book, which is both detailed and highly readable, is a practical response to that information gap. This first English edition is based on tax legislation which is effective in Luxembourg as at 31 December 2018 and provides guidance on how to complete the online corporate income tax, municipal business tax and net worth tax return for resident corporations and how to submit the mandatory electronic declaration. This book undertakes a page-by-page analysis of the tax return form for commercial companies and the annexes to that form and draws attention to the most important laws, regulations and administrative circulars currently in force. The book also incorporates many practical examples. These features make this book an ideal reference guide for resident corporations in Luxembourg.
Luxembourg - Agreement to Improve International Tax Compliance and with Respect to the United States Information Reporting Provisions Commonly Known a by The Law Library Pdf
The Law Library presents Luxembourg - Agreement to Improve International Tax Compliance and with respect to the United States Information Reporting Provisions commonly known as the Foreign Account Tax Compliance Act (15-729.1) (United States Treaty) Updated as of 02/21/19 This book contains: - The complete text of the Luxembourg - Agreement to Improve International Tax Compliance and with respect to the United States Information Reporting Provisions commonly known as the Foreign Account Tax Compliance Act (15-729.1) (United States Treaty) - A table of contents with the page number of each section
Transformation of the Luxembourg Tax Environment Towards the Post-BEPS Era by Oliver R. Hoor Pdf
Over the last years, the Luxembourg tax environment has undergone a comprehensive transformation following the OECD Base Erosion and Profit Shifting ("BEPS") Project and subsequent initiatives at EU level. 00With the transposition of the two Anti-Tax Avoidance Directives (?ATAD? and ?ATAD 2?) and the implementation of other tax measures into Luxembourg tax law, the Grand-Duchy contributed to a level playing field in international taxation. ATAD and ATAD 2 resulted in the implementation of a number of anti-abuse provisions including:0- Interest limitation rules;0- Controlled foreign company (?CFC?) rules;0- Hybrid mismatch rules;0- General Anti-abuse Rule (?GAAR?);0- Exit tax rules .00In addition, the Luxembourg legislator changed in 2019 the definition of permanent establishments (?PE?) and abolished the roll-over relief applicable to conversions of debt instruments into equity. 00This book provides a 360° view on the transformation of the Luxembourg tax environment.
Transfer Pricing in Luxembourg by Oliver R. Hoor Pdf
Over the last decades, Luxembourg has developed and cemented its position as a prime holding location and a major financial centre within Europe. Multinational enterprises and international investors alike use Luxembourg as a platform to manage their business activities and investments. 0Luxembourg companies may enter into diverse commercial and financial transactions with associated enterprises. The prices charged in regard to these controlled transactions are called transfer prices. For Luxembourg tax purposes, these prices have to adhere to the "arm?s length principle".0The arm?s length principle is the international transfer pricing standard that OECD member countries have agreed should be used for tax purposes by MNE groups and tax administrations. 0The arm?s length principle is firmly ingrained in Luxembourg tax law and has been explicitly stated in article 56 of the Luxembourg Income Tax Law (LITL). In addition, several concepts and provisions under Luxembourg tax law require the arm?s length standard to be respected by Luxembourg companies. 0In 2020, a new chapter X has been added to the OECD Transfer Pricing Guidelines that provides guidance on transfer pricing aspects of financial transactions which are a common phenomenon in Luxembourg. 0On 18 December 2020, the OECD further provided guidance on the application of the arm?s length principle and the OECD Transfer Pricing Guidelines to issues that may arise or be exacerbated in the context of the so-called COVID-19 pandemic and the financial turmoil resulting from government responses thereto.0This book analyses all facets of Luxembourg transfer pricing rules and relevant guidance in the 2020 version of the OECD Guidelines.
Luxembourg by International Monetary Fund. European Dept. Pdf
This Selected Issues paper considers features of the Luxembourg tax system that may be susceptible to changes in international tax transparency standards and surveys related policy options. Luxembourg’s predictable and generally low-rate tax system has helped establish it as a leading financial and commercial entrepôt and has supported its fiscal revenues. Its revenue base could, however, be susceptible to changes in the European Union and global tax environment. This paper highlights that to address potential challenges to Luxembourg’s revenue base, the tax policy review should explore selective rate increases and base broadening measures. Moreover, the tax practices should seek to avoid encouraging unnecessary complexity in corporate ownership structures and intragroup financial contracts.
The effect of the significant changes in tax law at domestic, European, and international levels on investment funds, an important part of global financial services, creates a complex environment for practitioners and a source of debate for academics and policymakers. This is the first book to provide a comprehensive legal and practical analysis of the changes to the complex multilevel tax and regulatory framework concerning different types of investment funds. The contributions, updated as of late 2017, were originally presented at a conference held at the University of Luxembourg in November 2016 under the auspices of the ATOZ Chair for European and International Taxation. The book covers the central questions arising in national law and tax policy, explores the regulatory and tax framework of the European Union (EU), and discusses the multifaceted interactions of both national and EU law with bilateral tax treaties. Through fourteen chapters following a brief introduction, leading academic experts and practising specialists provide decisive insight into: – the regulatory regime for European investment funds; – the tax law and reforms in both Luxembourg and Germany; – the role of the European Commission’s State-aid practices; – examples of case law concerning the application of non-discrimination rules to various investment vehicles; – the impact of tax-specific EU legislation, such as the Parent-Subsidiary Directive, the Tax Merger Directive, and the Anti-Tax Avoidance Directive; – the availability of tax treaty protection for different collective and non-collective investment funds; – the impact of base erosion and profit shifting (BEPS) developments on the taxation of cross-border investments; – the value-added tax (VAT) treatment of investment funds and their managers; and – the consequences of the global drive towards automatic exchange of information relating to existing cross-border investment structures. With its particular focus on Luxembourg – the leading centre for investment funds in Europe (and second only to the United States globally) and, thus, an instructive model for domestic-level investment fund regulation and taxation – this volume reveals the common issues that arise in virtually every other jurisdiction with a sizeable fund industry. As the first in-depth treatment of the globally significant nexus between investment funds and taxation, the book will prove valuable to policymakers, practitioners, and academics in both financial services and tax law.
Taxation of Investment Funds in the European Union by Tomi Viitala Pdf
The book analyses the taxation of investment funds and their investors from the standpoint of domestic tax laws, tax treaties and EC law. It also provides a comprehensive understanding of the tax issues arising in the cross-border transactions of investment funds and private fund investors in the European Union. The viewpoints of the source state of income, residence state of the investment fund as well as the residence state of the investor are all considered. The book takes a comparative approach by covering five EU Member States (the United Kingdom, Germany, France, Luxembourg and Finland). On the basis of the examination at the Member State level, the present tax rules and practices are tested against the fundamental freedoms of the EC Treaty. The conclusion is that there are still various tax measures that are likely to be in conflict with EC law. The book also discusses possibilities of adopting targeted measures of positive integration at the level of the European Union with a view to enhancing the objective of the single investment fund market.
Time and Tax: Issues in International, EU, and Constitutional Law by Werner Haslehner,Georg Kofler,Alexander Rust Pdf
Time is a crucial dimension in the application of any law. In tax law, however, where an environment characterized by rapid change on the national, European, and international levels complicates the provision of accurate legal advice, timing is particularly sensitive. This book is the first to analyse the relationship between time and three key areas of tax: treaties, EU law, and constitutional law issues, such as legal certainty and individual rights. Among the numerous timing issues arising out of applying tax rules, the book addresses the following: – time limits within which relief must be requested; – statutes of limitation for claiming a tax refund; – transitional issues relating to changes in tax treaties; – attribution of profits and expenses to a moving or closed-down business; – effect of tax-related CJEU decisions and EU directives; – compliance of exit tax regimes with free movement; – limits of retroactivity under principles protected by the EU Charter and the ECHR; and – conflict between efficiency of taxation and individual rights. Derived from a recent conference organized by the prestigious ATOZ Chair for European and International Taxation at the University of Luxembourg, the book brings together contributions from leading tax experts from various areas of tax practice, academia, and the judiciary. Among other issues, the book notably expands on how economic theory can inform a constitutional analysis of the timing of taxation. There is no other work that concentrates so usefully on the difficulties associated with applying tax rules – whether arising from treaties, jurisprudence, or policy – to changing circumstances over time. This book will quickly prove itself to be an indispensable resource for European tax lawyers, policymakers, company counsels, and academics.
Luxembourg by International Monetary Fund. European Dept. Pdf
Growth has been strong, benefiting from Luxembourg’s major role in intermediating international capital flows, and prospects are good. However, the outlook remains clouded by risks arising from possible global retreat from cross-border integration and policy uncertainty and divergence which could cause financial market volatility; from the international tax transparency and anti-tax avoidance agenda; as well as from new shocks to the euro area economy. Unemployment, moderately high relative to historical standards, mainly reflects skills mismatches, and new jobs have increasingly been taken up by cross-border commuters.
