- Orbitax

Luxembourg Tax News

Report on Attribution of Profits to PEs released

24 February 2007

EU Commission progresses infringement actions against Member States for discriminatory taxation of outbound dividends

24 February 2007

ECJ: previous UK ACT regime regarding outbound dividends compatible with EC fundamental freedoms (ACT IV GLO) – details

15 January 2007

ECJ holds French withholding tax on outbound dividends incompatible with freedom of establishment

15 January 2007

Protocol to treaty between Luxembourg and France signed

15 January 2007

Protocol to treaty between Luxembourg and France – erratum

17 December 2006

Bill on abolition of 1929 holding companies regime submitted to parliament

17 December 2006

Treaty between Luxembourg and Israel covers Luxembourg SICAVs and SICAFs and Israeli collective investment vehicles

12 November 2006

Parliament approves Bill implementing amendments to EC Parent-Subsidiary Directive

12 November 2006

French Parliamentary response on non-eligibility of Luxembourg SICARs to France-Luxembourg tax treaty and EC Parent Subsidiary Directive

12 November 2006

Budget for 2007 – details

12 November 2006

Luxembourg implements EU's European Company Statute

14 October 2006

Treaty between Luxembourg and Israel enters into force

14 October 2006

Protocol to treaty between Luxembourg and France – immovable property and business profit provisions amended

12 September 2006

European Commission requests Belgium to terminate discriminatory taxation of inbound dividends

13 August 2006

European Commission requested Spain to end infringement to the EC Parent-Subsidiary Directive concerning the use of anti-abuse measures

13 August 2006

European Commission decides that Luxembourg's preferential tax regime for 1929 holding companies constitutes incompatible state aid

13 August 2006

European Commission requests Belgium, Italy, Luxembourg, Netherlands, Portugal and Spain to terminate discriminatory taxation of outbound dividends

13 August 2006

European Commission refers Italy and Luxembourg to ECJ for not implementing Directive amending EC Parent-Subsidiary Directive

13 August 2006

Various tax rate changes announced

14 June 2006

Luxembourg Court

14 May 2006

Luxembourg

14 May 2006

Preliminary ruling requested from ECJ on compatibility of 3% tax on French immovable property held by non-resident companies with EC freedom of establishment and free movement of capital movement

14 May 2006

Treaty between Luxembourg and Israel ratified

9 April 2006

Different treatment of interest derived by Luxembourg PE of Belgian enterprise, and by Luxembourg fixed base of Belgian professional, under Belgium-Luxembourg treaty not incompatible with equality principle of Belgian constitution

9 April 2006

Advance ruling on Finnish withholding tax and EC Law re Luxembourg SICAV

9 April 2006

Treaty between Luxembourg and Denmark covers Luxembourg SICAVS and SICAFS and Danish collective investment vehicles

16 March 2006

Luxembourg and United Arab Emirates signed a first-time income tax treaty on 21 November 2005. Further details of the treaty will be reported subsequently.

6 December 2005

The first-time income and capital tax treaty, signed on 13 December 2004, between Luxembourg and Israel was presented to the Luxembourg parliament for approval on 7 October 2005. Once the treaty has entered into force, it will generally apply retroactively from 1 January 2004. The treaty was concluded in the French, Hebrew and English language, each text having equal authenticity, and generally follows the OECDE Model Convention.

9 November 2005

Netherlands dividend withholding tax on distributions to Luxembourg minority shareholder incompatible with EU law

9 November 2005

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