Olivier Sciales Taxation Law Blog

I.                   Introduction

The Luxembourg government has introduced by a law of 21 December 2007 a new Luxembourg IP regime (“Luxembourg IP Tax Law”) that provides for a 80% tax exemption of income derived from intellectual property (“IP”) as well as capital gains realized on the disposal of such intellectual property. The aim of... Read More

The Luxembourg - Hong Kong double tax treaty has entered into force on 20 January 2009 following the exchange of the ratification documents.

I set out hereunder the main features of this treaty. The maximum withholding taxes that will be applicable are as follows:

0% on dividends if the beneficial owner is a company that directly holds at least 10% in the capital of the distributing company or the participation has an acquisition cost of at least 1,200,000 Euro;... Read More

On 16 December 2008, the Luxembourg Parliament has passed laws to enact the attractive measures already proposed by the bills number 5924 and 5913.

The main measures introduced by these laws are as follows:

1. Abolition of capital duty as of 2009

The law has abolished the current contribution duty of 0,5% on capital contributions to Luxembourg companies.

The new favourable regime will provide:

- For  a fixed registration duty of 75 Euro on (i)... Read More

On 2 November 2007, Luxembourg signed a tax treaty with Hong Kong. The maximum withholding taxes that are set out are:

0% on dividends if the beneficial owner is a company that directly holds at least 10% in the capital of the distributing company or the participation has an acquisition cost of at least 1,200,000 Euro; 10% on dividends in all other cases; 0% on interests; and 3% on royalties paid from Hong Kong to Luxembourg. According to Luxembourg... Read More

On 1 October 2008, a draft bill (n¿5924) introducing new favourable tax rules was submitted to the Luxembourg Parliament. We set out hereunder a brief overview of the main changes that are proposed and that relate to companies:

The exemption of withholding tax on dividends paid to corporate shareholders located in countries with which Luxembourg has signed a double tax treaty. This expansion of the participation exemption regime would seriously enhance the attractiveness of... Read More