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Luxembourg Archive

  • August 2019

    What to expect at the IFA 2019 Congress

    August 09, 2019

    International Tax Review speaks to IFA President Murray Clayson about the prospects for “radical change” on digital tax and why the London Congress will focus on BEPS Action 4 and the challenges facing investment funds.

  • July 2019

    Survey results: Untangling CFC structures

    July 15, 2019

    Multinational businesses are simplifying structures to navigate the rules that target controlled foreign corporations (CFCs) and their shareholders. ITR asked those tax heads who have adopted this approach to share their business’s operational changes.

  • France and the US clash over digital service tax plans

    July 12, 2019

    The US has ramped up its opposition to France’s digital services tax (DST) by opening an investigation into it, but French senators have defiantly approved the so-called ‘GAFA’ tax anyway.

  • Global minimum taxation: A matter of time

    July 10, 2019

    Minimum tax red flags have appeared in recent legislation as countries and organisations race to address perceived inequities within the international tax regime.

  • Companies measure tax departments on their ability to cut risk, not effective tax rates

    July 10, 2019

    Managing tax risk is the most important metric by which tax departments are measured, with the more traditional target of lowering the company’s effective tax rate being less important to tax heads. However, CEOs seem to know little about tax KPIs and how, or why, they are chosen.

  • European Tax Awards 2019: The winners

    July 10, 2019

    The winners of International Tax Review’s 15th European Tax Awards have been announced.

  • Tax Advisory Survey 2019

    July 10, 2019

    Tax and trade wars among governments and the battles companies face against tax authorities through audits and inevitable disputes mean even the most super-human tax director among us needs a little help.

  • Only one way out: Simplifying CFC regimes

    July 10, 2019

    The number of countries adopting controlled foreign corporation (CFC) regimes has complicated business operations and forced them to change. Danish Mehboob talks to taxpayers who are trying to avoid getting lost in the labyrinth of multiple tax risks and unexpected audits.

  • Tax heads encourage more companies to use ICAP

    July 10, 2019

    Tax leaders from Barilla, Repsol and Shell have encouraged their contemporaries to sign up for the International Compliance Assurance Programme (ICAP), before the window to get involved closes later this month.

  • Case study: Repsol’s participation in ICAP

    July 10, 2019

    Rocío Bermúdez, tax global practices & transfer pricing senior manager at Repsol, spoke to ITR about her company’s participation in the first pilot of the International Compliance Assurance Programme.

  • The negative aspects of ICAP

    July 10, 2019

    While feedback on the International Compliance Assurance Programme (ICAP) has been overwhelmingly positive, unsurprisingly, the first pilot did encounter some teething problems.

  • OECD won’t rush ICAP expansion despite scheme’s popularity

    July 10, 2019

    The OECD’s Achim Pross says his ultimate aim is to expand the International Compliance Assurance Programme (ICAP), but companies may be disappointed to learn that it could be a relatively slow process.

  • UK tax transparent funds: Five years on from the first launch

    July 10, 2019

    Five years after the launch of the first UK authorised contractual scheme (ACS) – also known as the UK tax transparent fund (UK TTF) – in 2014, there are 22 UK TTFs in the market, with 172 sub-funds amounting to billions of assets under management. Mariano Giralt, Christopher Mitchell and Gildine Cassou look at the scheme’s impact.

  • Tax transformation: What companies need to know

    July 10, 2019

    In a wide-ranging interview, ITR speaks to Terri LaRae, partner and leader of the global operations transformation tax team at Deloitte, about the factors driving tax transformation and how tax departments can get the best out of it.

  • Luxembourg: Luxembourg adopts exit tax rules aligned with ATAD 1

    July 10, 2019

    The Luxembourg Parliament transposed the EU Anti-Tax Avoidance Directive 1 (ATAD 1) into Luxembourg legislation on December 21 2018

  • How concerned should companies be about data they send to tax authorities becoming public?

    July 10, 2019

    It’s interesting that the subject of data submitted to the tax authorities becoming public, either through a data leak or public country-by-country reporting (CbCR), is clearly still a significant concern among tax directors.

  • DAC6 fixes tax loopholes but confuses taxpayers

    July 08, 2019

    Banks are confused about how to follow the ‘vague hallmarks’ in the EU mandatory disclosure regime (DAC6).

  • June 2019

    Luxembourg’s intellectual property box regime: One year later

    June 06, 2019

    Luxembourg’s new and old IP regimes co-exist while the country gradually aligns itself with international tax standards. Taxpayers should not the criteria for the new intellectual property (IP) box regime.

  • May 2019

    EU changes VAT liability for transactions facilitated by digital platforms

    May 29, 2019

    Digital platforms have until December 2020 to prepare for changes introduced by the EU, which will require digital platforms to pay VAT on behalf of their non-EU sellers and on import of goods into the EU.

  • Exercising judgement as the head of tax

    May 28, 2019

    Heads of tax are called upon to make decisions continually, ranging from routine choices to the less frequent, but materially significant. Making decisions involves a combination of exercising judgement and drawing on structured processes to reduce risk writes Sandy Markwick, head of the Tax Director Network at Winmark.

  • Luxembourg: Luxembourg’s tax authority seeks verification of permanent establishments

    May 28, 2019

    On February 22 2019, Luxembourg's tax authority issued an administrative circular to clarify new rules surrounding permanent establishments. The Luxembourg law includes measures that amend the domestic definition of a PE to apply where a double non-taxation situation can arise under a tax treaty.

  • Reorganisations slow amid vague indirect transfer tax regimes

    May 16, 2019

    Uncertainty over how to tax offshore indirect transfers and delay to establishing an international framework for taxing such transfers is leading to a slowdown in corporate reorganisations.

  • April 2019

    Companies struggle with tax planning cost of Brexit despite another delay

    April 12, 2019

    The UK and EU have announced a six-month delay to Brexit – but companies and their tax departments are facing huge financial and opportunity costs nonetheless.

  • Media companies support digital taxation proposals

    April 05, 2019

    Media-related businesses are united in their desire to ‘level the playing field’ on taxing traditional and digital companies, but they do not all agree on the best way forward.

  • Tax Disputes Summit: Meet the speakers

    April 03, 2019

    Tax leaders from Acer, H&M, Swiss Re, the Portuguese Centre for Administrative Arbitration, the Finnish and Danish tax authorities, White & Case and William Fry speak to International Tax Review about trends, predictions and what is keeping them busy ahead of the ITR Tax Disputes Summit.

  • The world’s best tax transactional firms 2019

    April 03, 2019

    International Tax Review presents key trends and developments in the tax transactional market and ranks the best firms to help companies navigate the post-BEPS environment that poses challenges in restructuring and mergers and acquisitions.

  • Survey: Untangling CFC rules and regimes

    April 01, 2019

    Companies have to navigate a web of differing rules targeting controlled foreign corporations (CFCs) and their shareholders, but the process is far from easy when the distinctions in each country’s rules risk unexpected audits or an unreasonably high tax burden.

  • March 2019

    What you need to know before taking out tax insurance

    March 21, 2019

  • Stepping up: Companies get into the stride of post-BEPS tax transactions

    March 21, 2019

    After a buoyant start to 2018, M&A activity tailed off in the final quarter of the year. Despite this, for transactional tax, many large companies are restructuring as they adjust to the US Tax Cuts and Jobs Act, post-BEPS rules such as the EU Anti-Tax Avoidance Directive, and to the new reality of the digital economy.

  • Government and customers – the driving force of digitisation

    March 21, 2019

    Kim Hau, senior proposition manager for ONESOURCE Indirect Tax at Thomson Reuters, explains why corporate indirect tax teams must shift their approach from ‘surviving’ the compliance cycle to a more proactive and considered way of working.

  • Luxembourg: Luxembourg introduces CFC rules

    March 21, 2019

  • MNEs accept higher tax burden is inevitable at OECD digital tax consultation

    March 14, 2019

    Corporate tax heads at the OECD digital tax consultation in Paris admitted that they would need to bow to political pressure and accept potentially painful reforms.

  • Death of the European VAT return

    March 01, 2019

    The traditional periodic VAT return is headed for extinction. Avalara offer its country-by-country guide to how digital transaction reporting is sweeping through Europe.

  • February 2019

    Companies turn to insurance to push through M&A deals

    February 15, 2019

    Companies in the private equity and real estate sectors are increasingly turning to tax-specific insurance to expedite M&A deals.

  • Submit now for World Tax and World TP 2020

    February 11, 2019

    We are pleased to announce the official launch of World Tax and World TP 2020.

  • Investor pressure drives corporate tax policy development

    February 01, 2019

    Investors are giving serious consideration to their targets’ corporate tax policies before agreeing on the deal, but there are a number of companies that still have no such policy in place.

  • January 2019

    Financial institutions adapt to tax transparency

    January 28, 2019

    Tax transparency initiatives such as the CRS, AEOI and FATCA, and the upcoming mandatory disclosure rules, are having a profound impact on the operations and IT infrastructure of financial institutions (FIs) worldwide. Ronald Frey, chief product officer of the RegTech product unit within BearingPoint, discusses how these are creating trends towards data alignment and centralisation, and are changing the role of FIs and wealth managers in cross-border tax reporting.

  • The battle for resources: Making the case for tax departments

    January 28, 2019

    The rate of change in the tax regulatory environment in recent years has been rapid, arguably more so than at any other time in recent history. Heads of tax are competing with colleagues in other functions for a share of finite budgets. The challenge is to show value for money, writes Sandy Markwick, head of the Tax Director Network at Winmark.

  • Luxembourg: Luxembourg transposes the EU’s interest limitation rule into domestic law

    January 28, 2019

  • Not another tax department transformation

    January 28, 2019

    One of the principal subjects of discussion and analysis in tax in recent months is digitalisation. I am not only talking about the OECD, EU and unilateral proposals to address the taxation of the digital, or digitalised, economy, but also the potential of digital innovations to change business, tax administration and tax department processes.

  • EU’s majority voting proposal puts CCCTB back on the table

    January 21, 2019

    The common consolidated corporate tax base (CCCTB) and digital services tax (DST) could be introduced if the EU Commission’s proposal for qualified majority voting (QMV) succeeds.

  • DLA Piper hires Luxembourg tax partner and associate

    January 10, 2019

    Jacques Wantz joins the firm from Allen and Overy as a partner, and will be joined by Emre Akan as an associate.

International Correspondents