Luxembourg: Tax

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

On 22 August 2025, the Luxembourg tax authorities published a new circular L.I.R. n°168quater/2 dated 12 August 2025. It provides clarifications on the interpretation of the carve-out from the reverse...

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ATOZ

Luxembourg Tax Authorities Clarify CIV Exemption Criteria For Investment Funds

New guidance resolves key uncertainties under ATAD 2 reverse hybrid rules and provides immediate compliance roadmap for fund structures.

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Arendt & Medernach

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

Effective as of fiscal year 2022, a Luxembourg tax transparent entity may, under certain conditions, become subject to Luxembourg corporate income tax if its net income is not taxed as result...

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A&O Shearman

Luxembourg Reverse Hybrid Entity Rules: Clarifications Regarding The CIV Exemption

On 22 August 2025, the Luxembourg tax authorities issued a second circular (Circular) on the reverse hybrid entity rules, this time clarifying the exemption applicable to collective investment vehicles (CIV Exemption).

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Herbert Smith Freehills Kramer LLP

ATAD2 CIV Exemption Is Back In The Game!

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ELVINGER HOSS PRUSSEN, société anonyme

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

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Loyens & Loeff

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

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BSP

Draft Law 8590 | Carried Interest Tax Regime Overhaul

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BSP

Explaining The New Carried Interest Tax Regime

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Herbert Smith Freehills Kramer LLP

Luxembourg Submits Draft Law Transposing DAC9 And Amending Pillar Two Framework

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ATOZ

Carried Interest 2.0: Luxembourg Modernises Its Tax Treatment For Fund Managers

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Goodwin Procter LLP

Newsflash | Bill 8590 - Carried Interest Regime

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CMS Luxembourg

Luxembourg Government Releases Draft Law Implementing DAC8

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ATOZ

Luxembourg Carried Interest Taxation: Key Takeaways Of The Proposed New Regime

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ELVINGER HOSS PRUSSEN, société anonyme

Cross-border Remote Work | Remuneration Essentials (Video)

Luxembourg Employment

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Arendt & Medernach

ESG - Omnibus Package I CSRD & Taxonomy Changes

Luxembourg Commercial

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BSP

Hague 2019 Convention | Entry Into Force In The UK And Luxembourg Draft Law To Amend New Code Of Civil Procedure

Luxembourg Litigation

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BSP

EU Data Act: New Obligations For Data Holders Of Connected Products And Related Services

Luxembourg Privacy

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Loyens & Loeff

Long-Term Incentive Plans | Remuneration Essentials (Video)

Luxembourg Commercial

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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...

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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...

MG

Maples Group

News On Luxembourg Funds

Luxembourg Finance

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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

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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

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CMS Luxembourg

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

CL

CMS Luxembourg

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Income Tax

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

On 22 August 2025, the Luxembourg tax authorities published a new circular L.I.R. n°168quater/2 dated 12 August 2025. It provides clarifications on the interpretation of the carve-out from the reverse...

A

ATOZ

Luxembourg Tax Authorities Clarify CIV Exemption Criteria For Investment Funds

New guidance resolves key uncertainties under ATAD 2 reverse hybrid rules and provides immediate compliance roadmap for fund structures.

AM

Arendt & Medernach

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

On 22 August 2025, the Luxembourg tax authorities ("LTA") published a new Circular (L.I.R. nº 168quater/2, dated 12 August 2025) addressing certain aspects of the Luxembourg reverse hybrid mismatch rules ("RHMR").

Luxembourg Finance

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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

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

LL

Loyens & Loeff

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 2.0: Luxembourg Modernises Its Tax Treatment For Fund Managers

GP

Goodwin Procter LLP

See more

Transfer Pricing

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.

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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...

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ATOZ

European Court Further Clarifies Interplay Between VAT And Transfer Pricing

In a ruling of 3 July, the European Court offers further clarity on how intra-group transfer pricing arrangements should be treated for VAT.

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

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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

EU Tax Directives #1: Introduction To EU Tax Directives – New York Office Snippet

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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")...

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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.

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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.

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Arendt & Medernach

Corporate Tax In Luxembourg: What You Need To Know

European Union Tax

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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

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Loyens & Loeff

EU Tax Alert - Highlights 2024

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Loyens & Loeff

Luxembourg Introduces Tax Reforms To Enhance Competitiveness

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Harneys

ATOZ Insights - November 2024

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ATOZ

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Latest Videos

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SRS Legal

Rejestracja VAT – Na Co Zwrócić Uwagę Jako Przedsiębiorca?

KHG Hupajlo Grzegorczyk & Partners

Portugal Golden Visa Tax Rules: 2024 Update (Video)

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INGWE

Budget 2025 – Highlights And Insights – Video Commentary Analysis (Video)

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Byrne Wallace

2.5% Tax Rate For My Cyprus Company? I Did It! (Video)

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CYAUSE Audit Services Ltd

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