201607.20

New Company Law

On July 13, 2016 – after almost 10 years of steady maturation – the Luxembourg parliament adopted the bill of law 5730 modernising and amending the law of August 10, 1915 on commercial companies, the Civil Code and the law of December 19, 2002 on the trade and companies’ register and on the accounting and…

201406.13

European Commission – Apple, Starbucks and Fiat

On 11 June 2014, the European Commission opened a formal investigation procedure and issued two formal notices concerning alleged State aid against Luxembourg; these address the practice here of advance rulings on tax matters and the regime of intellectual property taxation. This initiative of the Commission follows extensive communication between the European Commission and the…

201403.21

Draft law 6633

Implements new tax treaties with the Czech Republic, Guernsey, Isle of Man, Jersey and Saudi Arabia and protocols to existing tax treaties with Denmark and Slovenia have been submitted to the Luxembourg Parliament. Written by Nicholas Martin – Coficom Trust S.à r.l. – Luxembourg

201403.21

Luxembourg Double Tax Treaties Network

Within its 2013 Annual Report, the Luxembourg Tax Authorities reported that they have negotiated several new double-tax treaties. These have been concluded with Hungary, New Zealand, United Kingdom and Uruguay.

201305.02

Old Style tax havens agree to disclose

More so-called old-style ‘tax havens’ have agreed to disclose the bank details of British taxpayers as part of the crackdown on evasion. The deal signed today commits Anguilla, Bermuda, the British Virgin Islands, Montserrat and the Turks and Caicos Islands to automatically share information with the UK. The British Overseas Territories will pass on names,…

201212.12

Annual Residential Property Tax (ARPT) – United Kingdom (UK)

The Treasury yesterday released the draft Finance Bill 2013 clauses in relation to the new annual charge, which will be called the “Annual Residential Property Tax” (ARPT). Details of the extension to CGT from April 2013 also emerged, although we will have to wait until January 2013 before the draft legislation is released. These follow…

201211.15

France: Renegotiation of the double tax treaty concerning real estate

France and Luxembourg are currently renegotiating. France requested for a renegotiation of the double tax treaty concerning capital gains coming from a real estate oriented company. France would like to avoid taxation under Luxembourg Law for operations relating to real estate located in France. Under the current double tax treaty capital gains from real estate…

201211.12

Taxation of UK Residential Property – Budget 2012

The UK Government Budget announced substantial changes to the structure of stamp duty land tax (SDLT) in the United Kingdom with immediate effect. In addition, two new charges on high value residential property owned by certain “non-natural” persons were introduced and are expected to come into force from April 2013, pending further consultations: An annual…

201210.12

Luxembourg-Poland: Amendments of the Double Tax Treaty

The amendments within the Luxembourg and Poland double tax treaty agreement have been signed on June 2012. This protocole introduces several changes to the current agreement for the avoidance of double taxation and the prevention of fiscal evasion regarding taxes on income and on capital.

201210.09

Solvency II – Updates

Below is a summary of the recent changes and developments in relation to the Solvency II Directive. These are: The European Union Council has published an information note on 13 July 2012 which states that the Council should be in a position to approve the proposed Directive amending the Solvency II transposition and application dates…