German Foreign Tax Act and Luxembourg Funds Executive Summary Effective 1 January 2022, investors in Luxembourg investment funds resident in Germany may be subject to controlled foreign corporation (CFC) rules under the German Foreign Tax Act if the investment fund invests in assets through subsidiaries not resident in Germany. CFC rules apply if an investor resident in …
ATAD III Knocking on Luxembourg’s Door: The Directive Proposal for Reporting Requirements Applicable to Shell Companies On 22 December 2021, the European Commission published a proposal for a Directive introducing rules against the use of shell companies in the European Union (Directive 2021/0434, hereafter the “Proposal”). The Proposal is also known in practice as …
ATAD III The Directive Proposal for Reporting Requirements Applicable to Shell Companies Read More »
On 27 July 2020, Luxembourg has published a law amending the reporting deadline regarding cross-border tax arrangements in Mémorial A No. 638. Therefore, the following reporting deadlines apply in Luxembourg: If the first step of an arrangement was implemented between 25 June 2018 and 30 June 2020, reporting can be made by 28 February 2021. If the first step of …
On 19 June 2020, we informed you about the decision of the European Council to allow EU Member States to extend the reporting period for cross-border tax arrangements as defined in the DAC 6 Directive by up to six months. The following extensions of the reporting deadline have been proposed: If the first step of an …
Commission proposes postponement of taxation rules due to Coronavirus crisis On 14 May 2020, we already informed about a proposal by the European Commission to postpone the original deadline for DAC 6 notification due to the restrictions during the COVID-19 pandemic. The Luxembourg Ministry of Finance endorsed this proposal in a publication of 4 June …
UPDATE : European Union postpones deadline for “DAC 6” Read More »
News radar: On 21 March 2020, the Luxembourg Parliament discussed and voted in favor of the bill implementing the DAC 6 Regulation in national law which was last amended by bill no 749510. The amended and now implemented bill (bill no 74959) extends the exemptions from the reporting obligations to expert-comptables, auditors, and lawyers and also …
Scope and Regulatory Facts In its fifth Directive 2018/822/EU (generally referred to as “DAC 6”) amending Directive 2011/16/EU on disclosure requirements for cross-border tax arrangements of 25 May 2018, the Council of the European Union requires the Member States to implement statutory reporting obligations for cross-border (tax) arrangements by 31 December 2019. The implementation of DAC 6 in the …
Amending Directive 2018/822/EU (“DAC 6”) in Luxembourg Read More »
Executive Summary With the law of 20 December 2019[1], Luxembourg has implemented the EU Directive ATAD II into national law with effect from 1 January 2020 by Articles 168ter and 168quater of L.I.R.[2] The directive as well as the law are intended to address so-called “hybrid mismatches” between associated enterprises and, in general, to take stronger action against tax-saving …
Anti-Tax Avoidance Directive II – Luxembourg Implements ATAD II Directive Read More »
Wir freuen uns, gemeinsam mit Ihnen das 5-jährige Jubiläum unserer Firma zu begehen. Seit 5 Jahren AIQUNITED! Am 28.03.2019 haben Sie mit uns im Le Quai in Grevenmacher gefeiert. Wir hoffen, Ihnen hat die Feier genauso sehr Spaß gemacht, wie uns. Hier ein kleiner Rückblick: Eröffnet wurde der Abend von Peter Kleingarn mit einem Tax …
German Tax Reporting and Partial Exemptions for German Investors Following the introduction of the new German Investment Tax Act (“InvStG”) of 1 January 2018, the new regulations must be taken into account for the first time at the level of the investors based in Germany when preparing tax returns for the tax year 2018. 1. …
German Tax Reporting and Partial Exemptions for German Investors Read More »
