Luxembourg Tax Authorities clarify application of EU Parent-Subsidiary Directive with respect to Gibraltar companies

On 1 December 2020, the Luxembourg Tax Authorities issued guidance¹ on the (non-) applicability of the Directive on the common system of taxation applicable in the case of parent companies and subsidiaries of different Member States (Parent Subsidiary Directive or PSD) to companies established in Gibraltar.

This Circular follows the decision of the Court of Justice of the European Union (CJEU) in the case of GVC Services (Bulgaria) EOOD (Case C-458/18), in which the CJEU confirmed …