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Luxembourg Tax News

ECJ: Advocate General holds German switch-over provision for low-taxed passive income of foreign PEs incompatible with EC Law – details

2 July 2007
ECJ: Swedish legislation on dividend tax relief in relations with third countries is compatible with EC law – details

2 July 2007
ECJ: German thin capitalization rules reclassifying interests paid to substantial shareholders in third States are not incompatible with EC law

2 July 2007
Treaty between Luxembourg and France – Luxembourg Administrative Court rules income of Luxembourg SA from French real estate owned by French SCI taxable in Luxembourg

2 July 2007
ECJ: Previous Austrian rules discriminating dividends received from third countries are compatible with free movement of capital under grandfathering clause – details

2 July 2007
Treaty between Belgium and Luxembourg – Luxembourg Administrative Court of Appeal decides denial of group tax treatment compatible with non-discrimination provision

2 July 2007
International tax conference on CCCTB held in Berlin

18 June 2007
Discussion draft on application and interpretation of non-discrimination article of OECD Model – details

18 June 2007
Revised Commentary on Article 7 of OECD Model released

28 May 2007
Bill to implement various EU Directives submitted to Luxembourg parliament

28 May 2007
US

28 April 2007
ECJ: temporal effects of judgment in Meilicke against Germany should not be limited – details

28 April 2007
New specialized investment fund regime introduced

28 April 2007
Final Report on Improving the Resolution of Tax Treaty Disputes

24 March 2007
Company tax regimes of Swiss cantons exempting foreign profits incompatible state aid under EU-Switzerland Agreement

24 March 2007
ECJ: hearing in case regarding Dutch withholding tax on outbound dividends

24 March 2007
Budget Law 2007 adopted

24 February 2007
EU Commission requests Italy not to apply a withholding tax on dividends paid to Netherlands parent companies

24 February 2007
EU Commission requests Italy to implement the Interest and Royalties Directive correctly

24 February 2007
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
Protocol to treaty between Luxembourg and France signed

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 – erratum

17 December 2006
Bill on abolition of 1929 holding companies regime submitted to parliament

17 December 2006
Parliament approves Bill implementing amendments to EC Parent-Subsidiary Directive

12 November 2006
Treaty between Luxembourg and Israel covers Luxembourg SICAVs and SICAFs and Israeli collective investment vehicles

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
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