Luxembourg: Views on the Luxembourg tax reform

International Tax Review is part of Legal Benchmarking Limited, 4 Bouverie Street, London, EC4Y 8AX

Copyright © Legal Benchmarking Limited and its affiliated companies 2025

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement

Luxembourg: Views on the Luxembourg tax reform

krawczykowski.jpg

Raymond Krawczykowski

Sustainability, justice, selectivity and competitiveness, were the hallmarks of Luxembourg's tax reform approved in December 2016. Amendments and targeted tax rate reductions, for both individuals and corporations, became effective on January 1 2017. The measures should help maintain Luxembourg's competitiveness as a location for companies to do business, but the government should continue to adopt additional tax reform measures to continue its progress.

The gradual reduction of the corporate tax rate, in particular, is welcome. For taxable income exceeding €30,000 ($32,000), the rate in 2017 is 19% (reduced from 21%) and will decrease to 18% in 2018. Thus, for a company located in Luxembourg City with taxable income exceeding €30,000, the tax rate will be 27.08% in 2017 (29.22% in 2016). Taking into account the corporate tax, the municipal business tax and the contribution to the employment fund, the rate for a company in Luxembourg City with taxable income exceeding €30,000 will be 27.08% in 2017 (29.22% in 2016). This rate will fall to 26.01% starting in 2018.

New EU tax rules and international tax guidelines, such as those relating to the OECD's BEPS Project, which was launched to combat tax base erosion and profit shifting, feature prominently in an increasingly globalised world. These measures, which are focused on promoting transparency, consistency and taxation in accordance with economic substance, represent unprecedented changes to the normative framework for taxation. Because taxation is a vector for competitiveness and growth, many are predicting that these changes to the tax rules will increase competition between countries.

If a country is to remain competitive, further reduction of the corporate tax rate should be considered, in addition to other tax measures.

For an example of one such measure, consider a tax regime that benefits intellectual property, such as an IP box regime. These types of regimes, applicable in many countries, including Luxembourg, recently have been abolished in some cases where the regime was not in line with the recommendations under the BEPS Project, with the possibility for companies that benefited from the regime before a certain date with certain conditions to continue under the regime until 2021. Some countries already have adopted new regimes in line with the new international standards. Despite the fact that Luxembourg has not yet taken similar measures, the attractiveness of Luxembourg is extremely high for alternative asset managers. A number of big players in the private equity, infrastructure, and hedge funds world have recently made some announcements about setting up their platform in Luxembourg – both their management entity and their investment funds. In addition, to stable tax policies and full compliance with the OECD tax framework, those fund managers have certainly taken the benefits of EU "passporting" of their funds into account as soon as their platform is registered in Luxembourg. It is, nevertheless, expected that the Luxembourg government should quickly put the announcements made in 2016 concerning additional tax reform into practice. These measures should include, among other items, a greater reduction in corporate taxation and the establishment of a new regime favourable to intellectual property, while respecting the new international tax guidelines.

Raymond Krawczykowski (rkrawczykowski@deloitte.lu)

Deloitte Luxembourg

Tel: +352 451 454 904

Website: www.deloitte.lu

more across site & shared bottom lb ros

More from across our site

Australian law firm Webb Henderson’s report said PwC had met 46 of 47 targets; in other news, the OECD has issued new transfer pricing country profiles
The arrival of a seven-strong team from Baker McKenzie will boost WTS Germany’s transfer pricing capabilities and help it become ‘a European champion’, the firm’s CEO said
Germany has forgotten to think about digital reporting requirements, a WTS partner claimed at ITR’s Indirect Tax Forum 2025
E-invoicing is currently characterised by dynamism, with fragmentation acting as a key catalyst for increasing interoperability, says Aida Cavalera of the International Observatory on eInvoicing
Pillar two and the US tax system ‘could work in harmony’, Scott Levine tells ITR in an exclusive interview to mark his arrival at Baker McKenzie
Peter White, who has a tax debt of A$2 million, has been banned for five years from seeking registration with Australia’s Tax Practitioners Board (TPB)
Wopke Hoekstra’s comments followed US measures aimed against ‘unfair foreign taxes’; in other news, Grant Thornton and Holland & Knight made key tax partner hires
An Administrative Review Tribunal ruling last month in Australia v Alcoa represents a 'concerning trend' for the tax authority, one expert tells ITR
A recent decision underlines that Indian courts are more willing to look beyond just legal compliance and examine whether foreign investment structures have real business substance
Following his Liberal Party’s election victory, one source expects Mark Carney to follow the international consensus on pillar two, as experts assess the new administration
Gift this article