Luxembourg: Corporate Tax

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Article
EU Securitisation Vehicles Likely To Continue To Be Exempt From Interest Limitation Rules
The European Court of Justice's Advocate General has delivered a significant opinion on whether Luxembourg properly implemented the EU Anti-Tax Avoidance Directive when it classified securitisation entities as exempt financial undertakings. The case examines whether Luxembourg's approach to exclude these entities from interest limitation rules aligns with EU law and the principle of equal treatment, with potential implications for how member states interpret ATAD's financial undertaking exemptions.
Luxembourg Tax
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CMS Luxembourg
Article
Luxembourg Private Funds Organised As Companies: How To Make Them Fit For Purpose
Luxembourg's partnership limited by shares (SCA) offers private fund managers a compelling corporate alternative to the special limited partnership structure, particularly for EU family offices and high-net-worth individuals. When combined with the RAIF regime, this vehicle achieves tax neutrality while maintaining the corporate governance framework that certain investors prefer. The SCA-RAIF structure addresses key legal and tax considerations while providing flexibility for secondary strategies, fund-of-f
Luxembourg Finance
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Loyens & Loeff
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