Eric Guillen

last day to register our pillar 2 webinar 🚀 🚀 🚀

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Newsflash | New tax circular on simplified liquidations tax regime On 19 July 2024, Luxembourg direct tax authorities issued circular L.I.R. n° 170/1, 170bis/1, I.C.C. n° 44, I.Fort. n° 55 (the “𝗖𝗶𝗿𝗰𝘂𝗹𝗮𝗿”) clarifying the Luxembourg tax treatment of the dissolution without liquidation under art. 1865bis of the Civil Code (also called in practice simplified liquidation or “𝘵𝘳𝘢𝘯𝘴𝘧𝘦𝘳𝘵 𝘶𝘯𝘪𝘷𝘦𝘳𝘴𝘦𝘭 𝘥𝘦 𝘱𝘢𝘵𝘳𝘪𝘮𝘰𝘪𝘯𝘦”). The Circular notably clarifies that for Luxembourg tax purposes, (i) the operation is governed by the rules applicable to mergers, thus being assimilated to a liquidation unless the relevant conditions are met to benefit from the tax neutral merger regime (domestic and cross-border) and (ii) the shareholder can continue any net wealth tax immunization reserve existing at the level of the dissolved company. 📌For more details, read the latest newsflash by our tax experts Gaëlle Felly and Ali Ganfoud: https://bit.ly/3WJpvsU 📍For more information about our Tax department, click here: https://lnkd.in/e5MhrCSb #bsp #newsflash #tax

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[ Offshore Tax ] PEA (Plan d’Épargne en Actions) :Tax Considerations. With Ron Murphy and Derren Joseph EA #PEA #FrenchInvestments #USTax #TaxDeferred #PFIC #USExpats #FATCA #FBAR #InvestmentAccount #TaxReporting #WorldwideIncome #TaxCompliance #RetirementSavings #ForeignAccounts #IRSCompliance

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Have your read the latest article published by AGEFI Luxembourg - Le Journal Financier de Luxembourg entitled "Transfer pricing: Current issues and recommendations for Luxembourg companies"? 🧐 In this article 📰 , our Tax Partner and Head of Transfer Pricing, Oliver R. Hoor, explains 🔎 the major impact on transfer pricing in Luxembourg due to a number of recent developments. Read this insightful analysis by clicking here 📲 https://lnkd.in/dkvxr9kC #transferpricing #tax #article #analysis #development #sharing #Luxembourg #ATOZ

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Marilène Marques, Deputy Head of Business Unit Legal Governance, Spuerkeess, and Nenad Ilic, CFA, Financial Services Tax Leader, PwC Luxembourg, who are closely involved in the ABBL's tax workstreams, share their expert views on the new FASTER Directive, which aims to streamline withholding tax procedures across the EU. 🚩 However, the implementation comes with its challenges, especially for financial institutions that must meet strict compliance obligations and manage significant workloads. Key highlights: 🔹 𝗗𝗶𝗴𝗶𝘁𝗮𝗹 𝗧𝗮𝘅 𝗥𝗲𝘀𝗶𝗱𝗲𝗻𝗰𝗲 𝗖𝗲𝗿𝘁𝗶𝗳𝗶𝗰𝗮𝘁𝗲 (𝗲𝗧𝗥𝗖): A standardised, EU-wide certificate issued within 14 days, confirming investors' tax residence. 🔹 𝗙𝗮𝘀𝘁-𝗧𝗿𝗮𝗰𝗸 𝗣𝗿𝗼𝗰𝗲𝗱𝘂𝗿𝗲𝘀: Relief at source and quick refund systems to ensure immediate application of the correct tax rate and timely refunds of excess tax. 🔹 𝗖𝗲𝗿𝘁𝗶𝗳𝗶𝗲𝗱 𝗙𝗶𝗻𝗮𝗻𝗰𝗶𝗮𝗹 𝗜𝗻𝘁𝗲𝗿𝗺𝗲𝗱𝗶𝗮𝗿𝘆 (𝗖𝗙𝗜): Large financial institutions will need to register as CFIs, complying with new obligations to collect eTRCs and assess investors’ eligibility for reduced rates. 🔗 Read the full article by our experts for an in-depth understanding: https://lnkd.in/emS5cP-M The ABBL is committed to supporting its members in the implementation of this new framework. We look forward to discussing potential challenges and finding solutions with all stakeholders. 🤝 👉 For more information or questions, please contact Laetitia Carroz, Senior Adviser - Tax at the ABBL.

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Tax optimisation rules: A good initiative from IESBA (International Ethics Standards Board for Accountants). Target is to hold financial experts accountable for their involvement in tax minimization strategies and to protect them from potential legal action. This is a direct impact link to tax avoidance scandals such as the Paradise Papers and Pandora Papers. The standard provides a framework for professional accountants, guiding them to consider reputational, commercial, and wider economic consequences in their tax advice. A new step forward in this long process of standardising AML

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Newsletter_TAX New draft bill containing different tax measures and clarifications – draft bill n°8388 On 23 May 2024, the Government submitted the draft bill n°8388 to the Parliament (“Bill”) clarifying the Luxembourg tax treatment applicable to share class redemptions, amending the minimum net wealth tax regime and introducing an opt-out mechanism for the “participation exemption” regime under specific conditions. Moreover, to continue the digitalisation of the income tax authorities, certain tax returns will be subject to mandatory electronic filings, notably withholding tax returns on directors’ fees. Read more on: https://lnkd.in/eNFuSj-i #tax #newsletter #directors

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Looking to stay ahead of the curve with the latest updates from the Luxembourg Accounting Board? 📕 Join us for an insightful training session coordinated by Alexandre Leleux, Damien Brunet, and gregory B. Our PwC's experts will delve into the newest doctrines and market impacts in accounting. Don't miss out! Register now for our session on 22 May 2024. ➡ https://lnkd.in/e-gxnYiF #accounting #accountingboard #luxembourg #training

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🚨The Administration des contributions directes (ACD) and the Administration de l’enregistrement, des domaines et de la TVA (AED) have signed a new agreement to enhance cooperation and data sharing, targeting tax avoidance more effectively. This move is part of a broader effort to modernize services and improve tax compliance. Finance Minister Gilles Roth calls it "a new milestone in our joint fight against tax fraud." #TaxCompliance #Luxembourg #TaxReform

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[#Newsflash] On 23 May 2024, the Luxembourg government tabled bill of law n°8388 (the “Bill”). Amongst other measures, the Bill clarifies the tax treatment applicable to the redemption of classes of shares, simplifies the minimum net wealth tax regime and introduces an opt-out mechanism for tax exemptions on dividends. #DentonsLuxembourg #Tax #Luxembourg

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📣 Luxembourg SPFs can request domestic #tax residency certificates On 4th June 2024, the Luxembourg tax authorities (#LTA) published the circular n°159/2 confirming that Luxembourg family wealth management companies (sociétés de gestion de patrimoine - SPFs), even if exempt from Luxembourg corporate income tax, can now obtain domestic tax residency certificates. The request for obtaining tax residency certificates must be duly motivated with an express reference to the foreign provision for which the tax residency certificate is required. Prior to the issuance of this circular, the LTA position was not to issue any type of tax residency certificates for Luxembourg SPFs. This change in the tax administrative practice is revolutionary since it allows SPFs to prove their tax residency status in Luxembourg with an official certificate issued by the LTA. If you have a Luxembourg SPF, contact a member of our tax team Rafael Moll de Alba and Rafael Lourenço. Please see the link to the circular n°159/2 issued by the LTA. https://lnkd.in/eYm7M545

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The Belgian Tax Authorities granted an extension of the notification deadline for Pillar 2/GloBE registration for groups that do not intend to prepay, until 16 September 2024. More details on the extension and registration on #KPMGTaxNow.

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💡 At the recently concluded CFE Tax Advisers Europe meeting in Brussels, the CFE New Tax Professionals Committee group, chaired by Anna Misiak, approved a report on improving soft skills among young tax advisers.   💫 While the CFE New Tax Professionals Committee is convinced that technical tax knowledge is the basis for the professional development of any tax professional, it has also identified significant value for a thriving, modern approach to tax advisory services in the appropriate level of soft skills such as problem solving, creativity, teamwork, responsiveness and communication within the organisation, both with clients and tax authorities.   Among others, the NTP identified the following topics as being of interest for the skill development of new tax professionals: 🔹 Communication skills 🔹 Conflict managementJ 🔹 Negotiation skills 🔹 Writing skills 🔹 Sales training and networking 🔹 Public speaking 🔹 Work-life balance 🔹 Prevention of job burnout and resilience training 🔹 Career expectations 🔹 Deontology 🔹 Leadership skills   #tax #taxes #taxadvisory #poland #CFE

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🇱🇺 The Administration des contributions directes (ACD) & the Administration de l'enregistrement, des domaines et de la TVA (AED) are stepping up their collaboration in the fight against #taxfraud. Last year, the two authorities recovered almost €1.5bn in #tax following tax reassessments. #Luxembourg https://lnkd.in/g-v45TCC

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📢 A bill of law (No. 8286) has been published on 28 July 2023 aiming at modernising Luxembourg accounting law and consolidating the accounting provisions into a single accounting law. 💡 How this bill will impact businesses in Luxembourg remains to be seen. Check out our latest newsflash for all the details! - https://lnkd.in/dSn3j5jZ   ☝ A question? Don’t hesitate to contact our experts: Mathieu Laurent (Avocat à la Cour, Partner), Anneleen Hofkens (Avocat à la Cour, Counsel), and Hajar Assebbane (Avocat, Managing Associate)   #Luther #LawFirm #unyer #Luxembourg #accountinglaw

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📢 The board of the Luxembourg Bar Association speaks out! The opinion from the board of the Luxembourg Bar Association on the proposed Bill of Law number 8286, aimed at modernizing the accounting legal framework, has been revealed! Released on May 6, 2024, this opinion is packed with insights and critiques that are bound to spark some serious discussions! 💼💡 💡 Here's a snapshot of the key points scrutinized by the board of the Luxembourg Bar Association: - Criticism towards the proposed mandatory requirement for systematic auditor reports on dividend payments for SAs, SEs, and SARLs, regardless of size. - Scrutiny over the elimination of auditors/supervisory boards in SAs, SASs, SARLs, and supervisory boards in SCAs. - Questioning the necessity of audits for "major holdings (grandes holdings)" due to associated costs, administrative burdens, and limited benefits. - Lack of clarity regarding financial statement deposits for certain SCSp companies and account balance requirements for others. - Disapproval with provisions of the Bill of Law mandating the approval of consolidated accounts by general assemblies. - Concerns over the proposed maximum duration of the first financial year. - Analysis of the new definition of "control" and its implications. - Advocating for electronic storage of accounting documents. - Critique on continuous verification of minimum share capital when financial statements are in a currency other than the euro. - Alarm raised against the concept of a floating financial year and its potential for accounting manipulation. - Insistence on maintaining the current liquidation procedure, opposing the removal of the second general meeting. 🔍 Curious to delve deeper? Click here to read the full opinion: https://lnkd.in/djN4WbRk 🔍 Got questions or need assistance navigating this legal maze? Reach out to Miroslava Jassova, our Legal counsel, for expert guidance and support. Want to revisit the original Bill of Law or explore related articles? 👉 - Brouxel & Rabia original article: https://lnkd.in/eArWwgCf - Brouxel & Rabia article summarizing the Opinion of the Order of Chartered Accountants on the Bill of Law : https://lnkd.in/e4fVVB8a - Link to the Bill of Law: https://lnkd.in/d3WQVAxU Don't miss out on this pivotal moment in Luxembourg's financial landscape! 💼💥 #LegalInsights #Opinion #LuxembourgBar #AccountingReform #LuxembourgLaw #brouxelrabia

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Elevate your expertise and expand your horizons at our upcoming seminar! Join us for a moment of learning, networking and growth! #RSMBelgium #Seminar #ProfessionalDevelopment #Learning

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Looking for an update regarding some actual tax topics? Subscribe to our tax seminar! #RSMBelgium #TAX #VAT

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