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;…
Corporate & Tax
10 October 2007
Proposal for a future decrease and abolition of Luxembourg capital duty
A Luxembourg bill on the Luxembourg 2008 Budget was introduced on 10 October 2007. The Luxembourg government has decided to gradually phase out the current capital duty of 1%. The proposal foresees a reduction from 1% to 0.5% starting on 1 January 2008 and a complete abolition by 2010 at the latest.
24 July 2007
The Law of 23 March 2007 has amended the Luxembourg company law
The law of 23 March 2007 has amended the Luxembourg company law (law of 10 August 1915). The major changes of this law are the following: extension of the mergers and divisions regimes (to all Luxembourg; companies, not only companies limited by shares “sociétés anonymes”); mergers and divisions can take…
12 March 2007
Abolishment of minimum par value requirement
The law of 21 December 2006 has amended the Luxembourg company law. It is no longer required that the shares issued by a société anonyme, a société en commandite par actions or a société à responsabilité limitée have a minimum par value per share. Prior to the new law, the minimum par value per share were [...]
20 November 2006
Draft law regarding SPF
On 20 November 2006, the Luxembourg government lodged bill number 5637, pertaining to the creation of a new investment vehicle, the private asset management company (société de gestion de patrimoine familial, also referred to as “SPF”. A private asset management company (SPF) can either adopt one of…
20 October 2006
New Luxembourg law – introduction of corporate governance measures
A Luxembourg law of 25 August 2006 has introduced new measures amending the Luxembourg company law. Hereunder, we briefly outline the main amendments. 1. Two-tier management and board structure A Luxembourg S.A. (société anonyme) will have the possibility to opt for a two tier structure instead of a one-tier structure. In…
17 October 2006
ECJ decision – Cadbury Schweppes – impact on Luxembourg
Summary of the judgment The European Court of Justice (ECJ) has on 12 September 2006 decided that the UK’s controlled foreign company (CFC) legislation can not be used to levy UK tax on the profits of low-taxed companies based in other EU member states, where such companies carry on genuine economic activities there.…
17 October 2006
New investment vehicle under discussion – SOGEPAF – alternative to holding 1929
A new investment vehicle designed for private investors will most probably be introduced in the next couple of months, currently named the SOGEPAF (“société de gestion de patrimoine familial“). A draft bill is currently under discussion but not yet set before Parliament to provide this new Luxembourg investment…
18 August 2006
New law on takeover bids – in the aftermath of the battle between Arcelor and Mittal Steel
As a result of a hostile takeover bid on 27 January 2006 by Mittal Steel on Arcelor, the Luxembourg parliament has adopted the law of 19 May 2006 pertaining to the implementation of Directive 2004/25/EC of the European Parliament and of the Council of 21 April 2004 on takeover bids (the “Takeover Law”). Previously…
9 August 2006
Real Estate – amendment of double tax treaty between France and Luxembourg – alternative structures
The double tax treaty between France and Luxembourg is about to be modified by an amendment which will change within the next months the conditions of taxation for Luxembourg companies holding real estate situated in France. Luxembourg and France have entered into a side-letter “avenant” to the double tax treaty (the…
Copyright © 2010 Chevalier & Sciales. All rights reserved. Terms of Use | Privacy Policy