On 27 July 2021, the tax authorities published updated guidelines on Article 22bis of the Luxembourg income tax law which sets out share exchange scenarios that may benefit from a tax deferral at the level of the Luxembourg shareholder. This circular replaces the previous version issued on 22 November 2002 and mainly takes into account amendments introduced by the Law of 21 December 2018 (through the abolishment of the tax neutral conversion of loans into shares).

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.