Deloitte Luxembourg

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.

Luxembourg has introduced controlled foreign company (CFC) rules for the first time in national legislation as part of its transposition of the EU's Anti-Tax Avoidance Directive (ATAD 1).

Luxembourg has transposed the EU's Anti-Tax Avoidance Directive (ATAD) into its domestic law, with the rules applying for financial years starting on or after January 1 2019.