Luxembourg Tax News

ECJ: hearing in case regarding transitional rules in respect of abolished German imputation system

4 November 2007

Treaty between Luxembourg and Hong Kong initialled

2 September 2007

Compatibility of exclusion of indirect ownership through companies in other EU Member States for French tax consolidation purposes with freedom of establishment referred to ECJ

2 September 2007

OECD releases revised draft of Part IV (Insurance) of the Report on Attribution of Profits to Permanent Establishments

2 September 2007

Treaty between Canada and Luxembourg – Canadian Federal Court of Appeal upholds Tax Court decision on non-applicability of general anti-avoidance rule to sale of shares

29 July 2007

EU Commission refers Greece to ECJ concerning discriminatory taxation of dividends

29 July 2007

ECJ: Interprets anti-avoidance clause under the Merger Directive with respect to Danish rules on taxation of exchanges of shares – details

29 July 2007

Second Guideline on implications of ECJ Denkavit case on French dividend withholding tax published

29 July 2007

ECJ: Finnish group contribution regime compatible with EC Law – details

29 July 2007

EU Commission progresses infringement procedure against Austria, Germany, Italy and Finland regarding taxation of outbound dividends

29 July 2007

ECJ: Advocate General finds Dutch withholding tax on outbound dividends incompatible with EC free movement of capital – details

2 July 2007

ECJ: Swedish legislation on dividend tax relief in relations with third countries is compatible with EC law – details

2 July 2007

ECJ: German thin capitalization rules reclassifying interests paid to substantial shareholders in third States are not incompatible with EC law

2 July 2007

Treaty between Luxembourg and France – Luxembourg Administrative Court rules income of Luxembourg SA from French real estate owned by French SCI taxable in Luxembourg

2 July 2007

ECJ: Previous Austrian rules discriminating dividends received from third countries are compatible with free movement of capital under grandfathering clause – details

2 July 2007

ECJ: Advocate General holds German switch-over provision for low-taxed passive income of foreign PEs incompatible with EC Law – details

2 July 2007

Treaty between Belgium and Luxembourg – Luxembourg Administrative Court of Appeal decides denial of group tax treatment compatible with non-discrimination provision

2 July 2007

International tax conference on CCCTB held in Berlin

18 June 2007

Discussion draft on application and interpretation of non-discrimination article of OECD Model – details

18 June 2007

Revised Commentary on Article 7 of OECD Model released

28 May 2007

Bill to implement various EU Directives submitted to Luxembourg parliament

28 May 2007

US

28 April 2007

ECJ: temporal effects of judgment in Meilicke against Germany should not be limited – details

28 April 2007

New specialized investment fund regime introduced

28 April 2007

Company tax regimes of Swiss cantons exempting foreign profits incompatible state aid under EU-Switzerland Agreement

24 March 2007

Final Report on Improving the Resolution of Tax Treaty Disputes

24 March 2007

ECJ: hearing in case regarding Dutch withholding tax on outbound dividends

24 March 2007

Budget Law 2007 adopted

24 February 2007

EU Commission requests Italy not to apply a withholding tax on dividends paid to Netherlands parent companies

24 February 2007

EU Commission requests Italy to implement the Interest and Royalties Directive correctly

24 February 2007