LUXEMBOURG

Implementation of the Anti-Tax Avoidance Directive in Luxembourg

On 19 June 2018, the Luxembourg Government has presented a bill to transpose the European Directive laying down rules against tax avoidance practices into Luxembourg law (Council Directive (EU) 2016/1164 of 12 July 2016). EU Member States must implement this Directive in national law by 31 December 2018. Hence, the new rules will apply from 1 January 2019. The aim of the European …

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New Double Tax Treaty Between Luxembourg and France

On 20 March 2018, France and Luxembourg signed a new bilateral tax convention for the avoidance of double taxation and the prevention of tax evasion with respect to income and wealth tax. Entering the post-BEPS era (OECD Action Plan on Base Erosion and Profit Shifting), the new treaty includes, for instance, the Principal Purpose Test …

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In Light of Recent Events: The AIFM Will Also Have to Express an Interest in the Pre-Marketing of “Its” AIFs in the Future

Background: Following the proposal of the European Commission for a Directive of the European Parliament and of the Council amending Directive 2009/65/EC [UCITS] of the European Parliament and of the Council and Directive 2011/61/EU [AIFMD] of the European Parliament and of the Council with regard to cross-border distribution of collective investment funds (2018/0041 (COD)[1], published on …

In Light of Recent Events: The AIFM Will Also Have to Express an Interest in the Pre-Marketing of “Its” AIFs in the Future Read More »

EVENT: AIQUNITED 19.03.2018

Ladies and Gentlemen, we would like to invite you to our event on Monday, 19.03.2018 at 18:30. Please find the program of the evening in the following: Greeting and Tax Update: Peter Kleingarn, Managing Partner AIQUNITED Luxembourg (in German) MiFID II/PRIIPS, General Data Protection Regulation and Transparency Register: Harald Strelen, Partner AIQUNITED Luxembourg (in German) …

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MiFID II – PRIIPs – GDPR – Transparency Register & No End in Sight for Luxembourg Investment Funds

Since the beginning of the year, at least two new regulatory gems have been added to the Luxembourg investment fund community. In the following, we would like to reiterate their effects on Luxembourg investment funds. First, there is the second Directive 2014/65/EU on markets in financial instruments (“MiFID II”), immediately followed by the Regulation (EU) 1286/2014/EU[1] on …

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German Withholding Tax on Distributions Made to Luxembourg Companies

CJEU Deems German Anti-Abuse Rule Set Forth in Paragraph 50d(3) of the EStG an Infringement   Executive Summary One of the most unfortunate German tax legislations was deemed an infringement by the Court of Justice of the European Union (CJEU) on December 20, 2017: Paragraph 50d(3) of the German Income Tax Act (Einkommensteuergesetz, EStG) pertaining to the …

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