Luxembourg: Government reveals business friendly programme

International Tax Review is part of Legal Benchmarking Limited, 1-2 Paris Garden, London, SE1 8ND

Copyright © Legal Benchmarking Limited and its affiliated companies 2026

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement

Luxembourg: Government reveals business friendly programme

odonnell.jpg

merle.jpg

Keith O’Donnell


Samantha Merle

The new Luxembourg government has released its programme, which includes positive tax measures and, more generally, contains encouraging messages for Luxembourg as a competitive location for business. Even if these are only announcements that will have to pass through the legislative process, many of the measures reflect a strong willingness of the government to make sure that Luxembourg remains a competitive jurisdiction within and outside the EU.

Luxembourg has over the last years run deficits and incurred government debt, although both at very modest levels by international standards. To restore budgetary stability, the government will prioritise cost reduction and growth, instead of increasing tax rates. In addition, compliance deadlines will be tightened and self-assessment will be introduced to accelerate collection of taxes.

Tax policy will be guided by the objective of creating confidence in a stable, predictable system. The only tax the government intends to increase is VAT, where the rate will, as expected, be increased to compensate the future loss in VAT revenues in the e-commerce sector. The government has committed to make sure that the Luxembourg VAT rate will remain the lowest in the EU however.

The government announced it will seek to attract headquarters of international groups, upgrading the intellectual property tax system, the parent subsidiary exemption regime, transfer pricing and substance rules, while making sure that Luxembourg is in line with all EU and OECD standards. A regime of notional interest deduction is also planned to stimulate businesses to increase their equity funding.

The government intends also to make sure that the Luxembourg legal and tax system in place is improved in such a way that it is in line with the needs and expectations of the marketplace and investors. Two measures illustrate this: the government announced that Luxembourg will formalise its ruling/advance tax agreement (ATA) practice, which should make the ATA system more efficient. In addition, to be aware of the needs of the market place, the government will establish an advisory committee of tax experts which will make concrete proposals to adapt the tax system to the needs of businesses/investors.

As far as the financial sector is concerned, the good news is that, contrary to what has been reported occasionally, the subscription tax due by undertakings in collective investment, be they alternative investment funds (AIFs), undertakings for collective investment in transferable securities (UCITS) or specialised investment funds (SIFs), will not be increased. Finally, the favourable carried interest regime which was introduced recently within the scope of the AIFM Directive is planned to be extended to all new investment funds set up in Luxembourg. Net wealth tax for individuals will not be reintroduced.

Luxembourg will remain against the introduction of a financial transaction tax at the level of the EU, but may agree to introduce one if this is done at global level.

The new Luxembourg government has released an ambitious programme with a lot of positive tax measures, which are welcome. Even though it remains to be seen how the tax measures will be implemented in practice, they reflect a clear aim to make sure that Luxembourg remains competitive.

Keith O'Donnell (keith.odonnell@atoz.lu) and Samantha Merle (samantha.merle@atoz.lu)

ATOZ – Taxand

Tel: +352 269 401

Fax: +352 269 40 300

Website: www.atoz.lu

more across site & shared bottom lb ros

More from across our site

An OECD report on taxation of the digital economy is expected by the end of 2026, according to the group of nations
Trophy assets are evolving from personal indulgences to structured investments, prompting family offices to prioritise tax efficiency, governance discipline, and cross-border compliance
As demand for complex, cross-border private client counsel spikes, Patrick McCormick sees opportunity in starting from scratch
As part of an exclusive global alliance, KPMG will become one of Anthropic’s ‘preferred consultants’ for private equity
In the second part of this series, the focus shifts to how taxpayers can manage ongoing risks across the lifecycle of cross-border structures
Jurisdictions have moved to ensure that multinationals are not punished for late GIR filings due to a lack of available filing portals or exchange relationships
HMRC’s push for unified tax adviser registration won’t prevent every instance of improper conduct, but it is good for taxpayers and the UK’s reputation
Elsewhere, the UAE’s tax office has issued an update on registration penalties and two firms have been busy making lateral hires
The case sits within a context of Brazil signalling that it is replacing informal discretion and ambiguity with structures that reward analytical rigour, one expert tells ITR
Jeff Soar lifts the lid on WTS UK’s ambitious recruitment plans, the firm's positioning against the big four, and why tax is the perfect profession for AI
Gift this article