86 results New double tax treaty concluded between Luxembourg and the United Kingdom: changes ahead Luxembourg and the United Kingdom signed a new Double Tax Treaty on 7 June 2022 which includes several changes that might have an effect on investments involving the two jurisdictions. Johan Léonard was interviewed by Paperjam Tax & Legal on the application of DAC6 Stibbe's Luxembourg tax partner Johan Léonard was amongst the few experts selected by Luxembourg's leading business publication Paperjam to discuss the implications of the DAC6 Directive in Luxembourg and throughout Europe. Dutch Supreme Court: non-resident investment fund eligible for refund of Dutch dividend withholding tax On 23 October 2020, the Dutch Supreme Court ruled that a non-resident UCITS fund is eligible for a refund of Dutch dividend withholding tax with respect to its investments in the Netherlands if strict criteria are met. Johan Léonard and Roberto de Castro Mendonça write on taxation of crypto assets Stibbe Luxembourg's tax lawyers Johan Léonard and Roberto de Castro Mendonça authored the Luxembourg chapter of the multi-jurisdictional book titled "Taxation of Crypto Assets". Do the math: ACM publishes strategy on monitoring use algorithms The ACM worries that the use of algorithms may lead to the creation of cartels, or nudge consumers towards a purchasing decision that is not in their best interest. Stibbe Luxembourg tax team writes on the taxation of cross-border workers in ACE Johan Leonard and Roberto de Castro Mendonça authored the article 'Taxation of Luxembourg cross-border workforce during the pandemic', which is featured in the latest issue of the professional periodical 'ACE'. A digital transition in the financial services sector On 24 September 2020, the European Commission (the “Commission”) adopted the Digital Finance Package (the “Package”). The aim of this initiative is to create a competitive EU financial sector that gives consumers access to innovative financial products. Introduction of dividend withholding tax in relation to low tax jurisdictions as per 2024 and update Dutch double tax treaty policy This Tax Alert will address two Dutch international tax policy proposals as included in letters that the Dutch State Secretary of Finance recently sent to the Dutch parliament on 29 May 2020. We note that the proposals are still subject to parliamentary d Online marketplace's liability for trademark infringement While online shopping is booming in such period of COVID-19 outbreak, the Court of Justice of the EU (CJEU) recently decided that Amazon cannot be accused of trade mark infringement. Chambers and Partners Real Estate Global Practice Guide 2020 - Luxembourg chapter Claire-Marie Darnand, Victorien Hémery, Johan Léonard, Tom Storck, Benjamin Marthoz, Audrey Jarreton and François Bernard have all contributed to the 2020 Chambers and Partners Real Estate Global Practice Guide, providing the Luxembourg chapter. Report of advisory committee on taxation of multinationals in the Netherlands The Dutch Lower House of Parliament adopted a motion that called on the Government to initiate and set up a committee of experts to explore fair multinational profit taxation. A report was submitted to Parliament last Wednesday (15 April 2020). Stibbe advises Mambu Stibbe advised Mambu, a market-leading, modern SaaS banking platform on raising €235 million in an EQT Growth-led Series E funding round, which is the largest financing round to date for a banking software platform. Tax Controversy: Update July 2021 This Alert addresses certain recent developments concerning procedural tax law in the Netherlands. We will discuss some interesting developments with regard to the (revised) Dutch tax ruling practice as per 1 July 2019 and the Tax Ruling Annual Report. Towards a European legal framework for the development and use of Artificial Intelligence Back in 2014, Stephen Hawking said, "The development of full artificial intelligence could spell the end of the human race." EU Commission presents proposals for directives against shell entities and ensuring a global minimum level of taxation On 22 December 2021 the European Commission (hereinafter: ‘EC’) presented two legislative proposals for EU directives, one to introduce a global minimum corporate tax rate and one to target EU shell entities. The key aspects of both proposals are discusse Luxembourg tax authorities issue circular providing guidance on the special real estate allowance On 30 May 2022, the Administration des Contributions Directes published a circular concerning the special real estate allowance. The Circular provides for some guidance on the computation of a special real estate rebate. Luxembourg real estate levy: Compliance obligations for Luxembourg investment vehicles As from 1 January 2021, a 20% real estate levy applies to real estate income derived by certain Luxembourg tax opaque investment vehicles owning directly, or indirectly through tax transparent entities, real estate assets located in Luxembourg. The Unshell directive and its impact on Dutch holding structures Charlotte Tolman and Michael Molenaars examine the European Commission's proposed Unshell directive, which targets the misuse of shell companies, and its potential impact on Dutch holding structures. 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New double tax treaty concluded between Luxembourg and the United Kingdom: changes ahead Luxembourg and the United Kingdom signed a new Double Tax Treaty on 7 June 2022 which includes several changes that might have an effect on investments involving the two jurisdictions.
Johan Léonard was interviewed by Paperjam Tax & Legal on the application of DAC6 Stibbe's Luxembourg tax partner Johan Léonard was amongst the few experts selected by Luxembourg's leading business publication Paperjam to discuss the implications of the DAC6 Directive in Luxembourg and throughout Europe.
Dutch Supreme Court: non-resident investment fund eligible for refund of Dutch dividend withholding tax On 23 October 2020, the Dutch Supreme Court ruled that a non-resident UCITS fund is eligible for a refund of Dutch dividend withholding tax with respect to its investments in the Netherlands if strict criteria are met.
Johan Léonard and Roberto de Castro Mendonça write on taxation of crypto assets Stibbe Luxembourg's tax lawyers Johan Léonard and Roberto de Castro Mendonça authored the Luxembourg chapter of the multi-jurisdictional book titled "Taxation of Crypto Assets".
Do the math: ACM publishes strategy on monitoring use algorithms The ACM worries that the use of algorithms may lead to the creation of cartels, or nudge consumers towards a purchasing decision that is not in their best interest.
Stibbe Luxembourg tax team writes on the taxation of cross-border workers in ACE Johan Leonard and Roberto de Castro Mendonça authored the article 'Taxation of Luxembourg cross-border workforce during the pandemic', which is featured in the latest issue of the professional periodical 'ACE'.
A digital transition in the financial services sector On 24 September 2020, the European Commission (the “Commission”) adopted the Digital Finance Package (the “Package”). The aim of this initiative is to create a competitive EU financial sector that gives consumers access to innovative financial products.
Introduction of dividend withholding tax in relation to low tax jurisdictions as per 2024 and update Dutch double tax treaty policy This Tax Alert will address two Dutch international tax policy proposals as included in letters that the Dutch State Secretary of Finance recently sent to the Dutch parliament on 29 May 2020. We note that the proposals are still subject to parliamentary d
Online marketplace's liability for trademark infringement While online shopping is booming in such period of COVID-19 outbreak, the Court of Justice of the EU (CJEU) recently decided that Amazon cannot be accused of trade mark infringement.
Chambers and Partners Real Estate Global Practice Guide 2020 - Luxembourg chapter Claire-Marie Darnand, Victorien Hémery, Johan Léonard, Tom Storck, Benjamin Marthoz, Audrey Jarreton and François Bernard have all contributed to the 2020 Chambers and Partners Real Estate Global Practice Guide, providing the Luxembourg chapter.
Report of advisory committee on taxation of multinationals in the Netherlands The Dutch Lower House of Parliament adopted a motion that called on the Government to initiate and set up a committee of experts to explore fair multinational profit taxation. A report was submitted to Parliament last Wednesday (15 April 2020).
Stibbe advises Mambu Stibbe advised Mambu, a market-leading, modern SaaS banking platform on raising €235 million in an EQT Growth-led Series E funding round, which is the largest financing round to date for a banking software platform.
Tax Controversy: Update July 2021 This Alert addresses certain recent developments concerning procedural tax law in the Netherlands. We will discuss some interesting developments with regard to the (revised) Dutch tax ruling practice as per 1 July 2019 and the Tax Ruling Annual Report.
Towards a European legal framework for the development and use of Artificial Intelligence Back in 2014, Stephen Hawking said, "The development of full artificial intelligence could spell the end of the human race."
EU Commission presents proposals for directives against shell entities and ensuring a global minimum level of taxation On 22 December 2021 the European Commission (hereinafter: ‘EC’) presented two legislative proposals for EU directives, one to introduce a global minimum corporate tax rate and one to target EU shell entities. The key aspects of both proposals are discusse
Luxembourg tax authorities issue circular providing guidance on the special real estate allowance On 30 May 2022, the Administration des Contributions Directes published a circular concerning the special real estate allowance. The Circular provides for some guidance on the computation of a special real estate rebate.
Luxembourg real estate levy: Compliance obligations for Luxembourg investment vehicles As from 1 January 2021, a 20% real estate levy applies to real estate income derived by certain Luxembourg tax opaque investment vehicles owning directly, or indirectly through tax transparent entities, real estate assets located in Luxembourg.
The Unshell directive and its impact on Dutch holding structures Charlotte Tolman and Michael Molenaars examine the European Commission's proposed Unshell directive, which targets the misuse of shell companies, and its potential impact on Dutch holding structures.