Luxembourg: Tax

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Reverse Hybrid Mismatches: Is The CIV Carve-out Finally Decoded?

In this episode, Johanna Tschurtschenthaler (counsel, Tax) and Chiara Wolf (associate, Tax) return to one of Luxembourg's most puzzling tax topics: the reverse hybrid mismatch rule under ATAD 2.

AO

A&O Shearman

Transfer Pricing Adjustments Within Multinational Groups May Be Subject To VAT: Milestone Decision By Court Of Justice Of The EU

The recent CJEU decision in Arcomet provides binding guidance on the VAT treatment of TP adjustments on intragroup services calculated using an OECD-recommended method.

AM

Arendt & Medernach

Welcome Clarifications On The CIV Exemption For Luxembourg's ATAD 2 Reverse-Hybrid Rules

Regulated funds, SIFs and RAIFs should automatically qualify for the CIV Exemption.

D

Dechert

Revamping The Carried Interest Regime In Luxembourg

To enhance Luxembourg's competitiveness and attractiveness for asset managers, the Luxembourg government has submitted bill No. 8590 (The Bill) to the Luxembourg parliament...

D

Dechert

Luxembourg Tax Authorities Clarify Reverse Hybrid Rules CIV Exemption Criteria

AM

Arendt & Medernach

Luxembourg Releases Circular On The CIV Carve-Out From The Reverse Hybrid Mismatch Rule

A

ATOZ

Luxembourg Tax Authorities Clarify CIV Exemption Criteria For Investment Funds

AM

Arendt & Medernach

Luxembourg Tax Administration Clarifies CIV Carve-out Under Reverse Hybrid Mismatch Rule

AO

A&O Shearman

Luxembourg Reverse Hybrid Entity Rules: Clarifications Regarding The CIV Exemption

KL

Herbert Smith Freehills Kramer LLP

ATAD2 CIV Exemption Is Back In The Game!

EH

ELVINGER HOSS PRUSSEN, société anonyme

Luxembourg Tax Authorities Clarify The "CIV Carve-out" Under The Reverse Hybrid Rules

LL

Loyens & Loeff

Landmark Decision On Qualification Of Financial Instruments & Non-recognition Of A Foreign Permanent Establishment

B

BSP

Draft Law 8590 | Carried Interest Tax Regime Overhaul

B

BSP

Explaining The New Carried Interest Tax Regime

KL

Herbert Smith Freehills Kramer LLP

Carried Interest: Luxembourg Opportunities | Remuneration Essentials (Video)

Luxembourg Finance

AM

Arendt & Medernach

EU Data Act: New Unfair Contractual Terms In B2B Data-Sharing Agreements

European Union Privacy

LL

Loyens & Loeff

Long-Term Incentive Plans | Remuneration Essentials (Video)

Luxembourg Commercial

AM

Arendt & Medernach

Pension & Employee Benefits | Remuneration Essentials (Video)

Luxembourg Employment

AM

Arendt & Medernach

Q2 2025 Wrap-Up On Sustainability | Eyes On ESG (Video)

Luxembourg Commercial

AM

Arendt & Medernach

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Related Country Guides

Tax Treaties

Luxembourg Announces Competitive New Tax Regimes For Carried Interest

On 24 July 2025, Luxembourg's government released a bill of law aimed at expanding the scope of the tax regimes for carried interest earned...

LL

Loyens & Loeff

ATAD 3 / Unshell Directive Proposal Officially Dropped!

After being stalled at the draft stage for over three years, it results from the ECOFIN report 9960/25 of 18 June 2025...

EH

ELVINGER HOSS PRUSSEN, société anonyme

Luxembourg Replaces Tax Treaty Benefits And UCI Residency Certificates Circular

On 24 December 2024, the Luxembourg tax authorities ("LTA") issued Circular L.G.- A n°61 ("Circular") which updated the guidelines on the issuance of tax residency certificates for undertakings for collective investments...

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Maples Group

News On Luxembourg Funds

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Arnone & Sicomo

EU Adopts FASTER Directive: A Milestone For Streamlining Withholding Tax Relief

European Union Tax

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Arendt & Medernach

Luxembourg Circular N° 821 Introduces New Digital Forms For UCI, SIF, And RAIF Subscription Tax Filings

Luxembourg Finance

CS

Chevalier & Sciales

CJEU Rules That Dutch Interest Deduction Limitation Rule Is Not In Breach Of EU Law

European Union Tax

LL

Loyens & Loeff

Back To Basics | Reserved Alternative Investment Fund ("RAIF") In Luxembourg

CL

CMS Luxembourg

Back To Basics | Specialised Investment Fund ("SIF") In Luxembourg

CL

CMS Luxembourg

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Income Tax

Reverse Hybrid Mismatches: Is The CIV Carve-out Finally Decoded?

In this episode, Johanna Tschurtschenthaler (counsel, Tax) and Chiara Wolf (associate, Tax) return to one of Luxembourg's most puzzling tax topics: the reverse hybrid mismatch rule under ATAD 2.

AO

A&O Shearman

Welcome Clarifications On The CIV Exemption For Luxembourg's ATAD 2 Reverse-Hybrid Rules

Regulated funds, SIFs and RAIFs should automatically qualify for the CIV Exemption.

D

Dechert

Revamping The Carried Interest Regime In Luxembourg

To enhance Luxembourg's competitiveness and attractiveness for asset managers, the Luxembourg government has submitted bill No. 8590 (The Bill) to the Luxembourg parliament...

D

Dechert

Luxembourg Tax Authorities Clarify Reverse Hybrid Rules CIV Exemption Criteria

AM

Arendt & Medernach

Luxembourg Releases Circular On The CIV Carve-Out From The Reverse Hybrid Mismatch Rule

A

ATOZ

Luxembourg Tax Authorities Clarify CIV Exemption Criteria For Investment Funds

AM

Arendt & Medernach

Luxembourg Clarifies The Exclusion For Collective Investment Vehicles - Key Points For Investment Funds

Luxembourg Finance

CL

CMS Luxembourg

Luxembourg Tax Administration Clarifies CIV Carve-out Under Reverse Hybrid Mismatch Rule

AO

A&O Shearman

Luxembourg Reverse Hybrid Entity Rules: Clarifications Regarding The CIV Exemption

KL

Herbert Smith Freehills Kramer LLP

See more

Transfer Pricing

Transfer Pricing Adjustments Within Multinational Groups May Be Subject To VAT: Milestone Decision By Court Of Justice Of The EU

The recent CJEU decision in Arcomet provides binding guidance on the VAT treatment of TP adjustments on intragroup services calculated using an OECD-recommended method.

AM

Arendt & Medernach

Landmark Decision On Qualification Of Financial Instruments & Non-recognition Of A Foreign Permanent Establishment

On 17 April 2025, the Luxembourg Higher Administrative Court (Cour administrative), delivered its long awaited decision on case n° 50.602C pertaining to the qualification of interest free loans under Luxembourg tax law and the existence of a permanent establishment in a treaty jurisdiction.

B

BSP

Luxembourg Government Releases Draft Law Implementing DAC8

On 24 July 2025, the Luxembourg government released a draft law aimed at implementing Council Directive 2023/2226 dated 17 October 2023, the so-called "DAC8", amending Directive 2011/16/EU...

A

ATOZ

European Court Further Clarifies Interplay Between VAT And Transfer Pricing

European Union Tax

LL

Loyens & Loeff

EU Tax Directives #5: Proposed EU Transfer Pricing Directive – New York Office Snippet

European Union Tax

LL

Loyens & Loeff

Transfer Pricing Adjustments And VAT For Multinational Groups: Latest CJEU Developments

AM

Arendt & Medernach

Advocate-General: TP Adjustments May Have VAT Implications

European Union Tax

LL

Loyens & Loeff

Tax Update In Luxembourg Regarding Interest Rates For Shareholder Current Accounts

GP

Goodwin Procter LLP

Welcome Clarification On Dutch Transfer Pricing Mismatch Legislation Scope In Respect Of Deemed Dividend Distribution Due To Non-arm's Length Transaction Between Foreign Subsidiaries

LL

Loyens & Loeff

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Corporate Tax

Luxembourg Submits Draft Law Transposing DAC9 And Amending Pillar Two Framework

On 24 July 2025, the Luxembourg government released the draft law No. 8591 ("the Draft Law") transposing the Directive (EU) 2025/872 ("DAC9")...

A

ATOZ

ATOZ Insights - May 2025

As spring is upon us, the time has come to present our latest edition of our Insights, highlighting recent developments from the Grand Duchy, at European level, and in the Middle East over the past few months.

A

ATOZ

Start-Up Tax Credit For "Business Angels": Legislation Introduced Into Luxembourg Parliament

In March 2025, the Ministers of the Economy and Finance jointly unveiled a 10-point action plan to boost Luxembourg's start-up and scale-up ecosystem.

AM

Arendt & Medernach

Corporate Tax In Luxembourg: What You Need To Know

European Union Tax

LL

Loyens & Loeff

2025 Tax Playbook: 10 Key Changes You Need To Know

LL

Loyens & Loeff

Pillar Two: Jan. 2025 OECD Guidance (Part 1) – New York Office Snippet

European Union Tax

LL

Loyens & Loeff

EU Tax Alert - Highlights 2024

LL

Loyens & Loeff

Luxembourg Introduces Tax Reforms To Enhance Competitiveness

H

Harneys

ATOZ Insights - November 2024

A

ATOZ

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