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The Council of the EU announced on 12 December 2022 that the EU Member States had unanimously reached agreement on the directive on the implementation of Pillar Two. It formally adopted the directive three days later.

The Luxembourg Tax Authorities (“LTA”) published a circular letter concerning the application of the reverse hybrid rules (the “Circular”) . The Circular provides guidance on the determination of tax owed by Luxembourg reverse hybrid entities.

In mid-January 2023, the European Parliament approved the European Commission’s draft directive to prevent misuse of shell entities for tax purposes (known as ATAD 3), as amended by its Committee on Economic and Monetary Affairs.

On 12 September 2023, the European Commission published a proposal for a Council Directive on Business in Europe: Framework for Income Taxation (BEFIT Directive).

The new double tax treaty between Luxembourg and the United Kingdom (“DTT”) ratified by the Luxembourg Parliament on 19 July 2023 should apply as from 2024.

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On 20 December, the Luxembourg Parliament adopted bill of law 8292 implementing Council Directive 2022/2523 on ensuring a global min. level of taxation for multinational enterprise groups & large-scale domestic groups in the EU, also known as Pillar Two.

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

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.

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.

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.

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.