The Administrative Court of Luxembourg recently issued a judgment regarding the beneficial ownership requirements for the partial exemption on trademark license income under the country's prior IP regime. The judgment concerns two joined cases involving a Luxembourg company of a Canadian group that acquired the exclusive rights to trademarks from a U.S. group company, which were sublicensed to other European group companies. For tax years 2015 and 2016, the Luxembourg company claimed an 80% exemption on income received from sublicensing the trademarks. This was denied by the tax authority, which held that the company could not claim the exemption because...