On July 17, 2024, the Luxembourg government introduced Bill No. 8414, a multifaceted tax reform initiative designed to bolster the country's global competitiveness. This legislation introduces significant changes to corporate and individual tax structures, with a particular focus on enhancing Luxembourg's financial sector.
One of the most notable measures is the exemption of actively managed Exchange-Traded Funds (ETFs) from subscription tax. This exemption widely supported by industry experts, is expected to stimulate the development of active ETFs—a rapidly growing segment that combines the liquidity and tax efficiency of traditional ETFs with active management strategies. To qualify, the ETFs must trade throughout the day on at least one regulated market or multilateral trading facility (MTF), with a market maker ensuring price stability.
Starting in 2025, Luxembourg's corporate income tax (CIT) rate will decrease from 17% to 16%, lowering the overall tax burden in Luxembourg City from 24.94% to 23.87%. This reduction is aimed at making Luxembourg more attractive for businesses, particularly in the finance and asset management sectors. To attract highly skilled foreign workers, the bill introduces reforms to the impatriate regime, offering a 50% tax exemption on gross annual remuneration up to €400,000. Simplifying the qualification process for expats is expected to reduce bureaucratic barriers, helping companies hire international talent, particularly in emerging sectors like fintech and sustainable finance.
The bill raises the tax-exempt portion of profit-sharing bonuses from 25% to 30% of an employee's gross annual remuneration. Additionally, companies can now allocate up to 7.5% of their positive operating results toward profit-sharing bonuses. This adjustment promotes employee participation and encourages businesses to reward employees more equitably, improving morale and retention.
On the individual level, Bill No. 8414 includes revisions to personal income tax brackets, which have not been updated since 2017. These changes aim to ease the tax burden on low-income households and protect wage growth from inflationary pressures. The elimination of taxes on minimum wage earners further reflects the government's commitment to social equity.
If passed, Bill No. 8414 is set to take effect on January 1, 2025. Finally, it is expected that the tax reforms targeting both corporate entities and individuals will help drive investment, attract talent, and ensure that Luxembourg remains at the forefront of global finance.
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