Arendt & Merdernach
On 7 November 2013, the Luxembourg VAT authorities published a circular (Circular n° 723ter) on the VAT treatment applicable to risk management for investment funds. The VAT authorities confirmed that risk management functions are to be considered as forming part of VAT exempt fund management services.
Topics: Introduction of the bill creating the family foundation, New circular letter on minimal lump-sum corporate income tax, Participation exemption regime not applicable to French SCI companies (Case No. 31981C), Concept of intellectual property rights constitution (Case No. 30215), Crédit Lyonnais VAT case (C-388/11): no worldwide prorata of deduction for head offices, Tax treaty network, Exchange of information - Peer review report - Phase 2, Recent tax treaties applicable to Luxembourg SICAVs and SICAFs
Topics: Adoption of the law on alternative investment fund managers, New circular letter on the Luxembourg tax regime for impatriates, New circular letter on calculation of partial input VAT deduction right, Latest case law on exchange of information, Qualification of storage services as property related services for VAT purposes (Case C-155/12 - RR Donnelley Poland), Contractual terms not decisive for VAT purposes (Case C-653/11 - Paul Newey), Refusal to treat share sales as a transfer of a going concern for VAT purposes (Case C-651/11 - X), Update on Directive 2003/48/EC on taxation of savings income, Proposed amendments to Directive 2011/16/EU on administrative cooperation, Update on FATCA, VAT decisions at Ecofin meeting, EU study on VAT ruling requests, Double tax treaty network
Topics: administrative cooperation, deferred taxation of unrealised capital gains upon migration, new VAT provisions, recent case law, supply of insurance services, refusal to assign a VAT identification number, VAT exemptio, VAT treatment, audiovisual investment certificate tax regime, constitution of the contribution to the chamber of commerce, double tax treaty network
Topics : fight against money laundering and terrorist financing, criminal settlement, electronic achieving, remuneration policies of AIFMs, AIFMD implementing measures.
CJEU confirms VAT exemption of investment advice for funds.
Topics: new tax measures, stock option plans, business succession, exchange of information, VAT changes, Luxembourg and France VAT rates on e-books, case law on VAT, double tax treaty network.
Important step towards the VAT exemption of investment advice for funds
Topics: Banking secrecy, Luxembourg law of 21 July 2012, General Court’s MasterCard judgment, Professionals of the insurance sector, Special Limited Partnership (SLP) Regime, ESMA Q&A on KIID for UCITS, European regulation.
Topics: budget law, cooperation in the field of taxation within the EU, new VAT and income tax provision, transfer of shares’ usufruct, Luxembourg net wealth tax exemption, case law on VAT, double tax treaty network, VAT matters.
Topics: Package Retail Investment Products (PRIPS), Insurance Mediation Directive (IMD2), UCITS V.
Topics: French withholding tax on national sourced dividends can be recovered by non-resident UCITS, new tax treaty between Germany and Luxembourg, double tax treaty between Luxembourg and Poland, non-US resident taxpayers, case law on VAT.
New Germany - Luxembourg double tax treaty signed
Topics: Luxembourg & international news, mutual agreements concluded between Luxembourg and Germany, double tax treaties network.
Further to our Tax Seminar in Luxembourg on 21 October 2013, please find attached the conference slides.>>
Further to our AIFMD Seminar in London on 10 October 2013, please find attached the conference slides.>
Alain Goebel will be a speaker at the IAML annual congress on 18 September 2013 in Buenos Aires, Argentina.>
Further to our conference "Get up to speed with recent international tax and VAT developments affecting Luxembourg" held in Luxembourg on 20 September 2012, please find attached the conference slides.>
Jan Neugebauer was a speaker at the 5th Annual Worldwide Tax Update on "Luxembourg Tax Law Developments " on 15 May 2012 in Boston and on 16 May 2012 in New-York.>
Jan Neugebauer was a speaker at the European Direct Taxation seminar on "Cross border payments of interest and royalty" on 8 May 2012 in Treves.>