New IP regime in Luxembourg – The Challenges and ideas- 1

In Uncategorized by Michael Probst

In this Blog article called “The Challenges – Part I”, I will publish my views on the transition between the old and the new IP tax regime, and the IP which will no longer qualify under the new regime as well as some planning opportunities with regard to such IP. Indeed, the so-called “grandfathered” IP will continue to benefit from …

New IP regime in Luxembourg

In Uncategorized by Michael Probst

Finally, Luxembourg has managed to issue new tax rules on IP held through Luxembourg companies. A draft bill waited for desperately. Even though the tax benefit is 80% of net income (a known percentage), there have been some amendments, to ensure the new regime is in line with the OECD’s Nexus Approach. Indeed, the new regime will be more restrictive …

Transfer pricing – the head-cracker of Luxembourg tax advisers in the future?

In Uncategorized by Michael Probst

Unfortunately, I believe that the reply to the question I asked myself is: “Yes”. While the focus in Luxembourg currently is the transfer pricing circular for intra-group financing in its new version dated 27 December 2016, I think that the large wording of Article 56bis of Luxembourg Income Tax Law – which is by no way restricted to group financing, …