ATOZ Insights - November 2024

Greetings!

The leaves have fallen from the trees, the first frosts and snow are making a timid appearance, and 2024 is nearly over. This brings us to our annual year-end Insights edition highlighting what has happened in the Grand-Duchy and at European level in the past few months.

The newly elected Luxembourg government quickly made tax proposals to implement its coalition agreement. Over the past few months, several draft laws have been presented by the Luxembourg Government which include (direct) tax changes to strengthen Luxembourg’s attractiveness and are still pending before Parliament. We will describe the state of play of these tax initiatives and the likely timing for their adoption.

On 19 July 2024, the Luxembourg tax authorities also released a new circular which deals with the tax treatment of  dissolutions without liquidation for corporate income tax, municipal business tax and net wealth tax purposes. We will analyse the implications of the new circular regarding greater legal certainty

While the Luxembourg government has been very active in proposing new tax measures, at European level, on the contrary, 2024 was relatively quiet. We will explain hereafter the progress of the various tax initiatives at EU level during the past few months.

On 29 July 2024, the Court of Justice of the European Union issued a judgment upholding various provisions of DAC6 as infringing neither the principles of equal treatment and non-discrimination nor the general principle of legal certainty or the right to a fair trial and the right to privacy. We will analyse below the reasoning of the CJEU.

Finally, as part of the Green Deal and to become the first climate neutral continent by 2050, the EU has notably introduced the Corporate Sustainability Reporting Directive (CSRD) as a new regulation for sustainability reporting. We will explain below the implications of the CSRD for European companies.

We hope you enjoy reading our Insights.

The ATOZ Editorial team