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As local and international tax regulations become more prescriptive, dealing with them in a cross-border context presents you with a significant challenge. The number and complexity of tax investigations conducted by authorities is rapidly escalating and the need for tax adjustments is rising accordingly. Luxembourg being a key jurisdiction in cross-border tax structuring, we understand the tax pressures you face. That is the reason why we endeavour to provide you with innovative and tailor-made solutions.

Whether you are a financial institution, multinational, fund, investor or high net worth individual, CMS Luxembourg Tax team can help you manage tax control cases and deal with tax authorities as well as manage tax litigation cases. The right tax advice can make a material difference to transaction costs and, in some cases, avert serious consequences.

CMS Luxembourg’s Tax lawyers are able to provide advice on a vast range of transactions to both domestic and international clients. As an example we regularly assist our funds department on the tax aspects of the structuring of regulated and unregulated real estate, private equity or debt assets funds. In addition, we are able to cover most of the countries in which you are doing business thanks to our close collaboration with highly qualified CMS experts.

Indeed CMS alliance is composed of more than 350 tax lawyers who are supported by strong technical tax intelligence teams that identify developments in tax law and policy affecting your business. This multi-disciplinary approach helps you develop robust structures that maximise tax effectiveness in alignment with your commercial strategy.

Our teams work together across Europe and beyond in the key areas affecting your business including VAT, international taxation, transfer pricing, e-commerce, M&A and investment funds, tax planning and financing.

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Daniel Gutmann
06/06/2018
Tax avoid­ance in a glob­al­ised world
28/09/2018
CMS - Fo­cus­ing on Funds - Tough­er Tax Rules for Ger­man Real Es­tate
This Fo­cus­sing on Funds up­date looks at the con­tinu­ing hot top­ic of how tax changes af­fect fund struc­tures and deals. Fol­low­ing our pre­vi­ous look at the France and Lux­em­bourg double tax treaty, the fo­cus be­low is on Ger­man real es­tate.
May 2018
Ar­ti­fi­cial In­tel­li­gence and Ro­bot­ics: From a La­bour...
#law­volu­tion
29/06/2018
Changes in the works for real es­tate trans­fer tax in share deals
At the 21 June 2018 Ber­lin meet­ing of fin­ance min­is­ters of Ger­many's fed­er­al states, dis­cus­sions around ap­ply­ing the real es­tate trans­fer tax to share deals entered a new phase. The fin­ance min­is­ters agreed to the fol­low­ing meas­ures: Cre­ation of a new.
11/06/2018
BEPS: UK rat­i­fies the OECD Mul­ti­lat­er­al In­stru­ment
The Double Tax­a­tion Re­lief (Base Erosion and Profit Shift­ing) Or­der 2018 has been ap­proved by the House of Com­mons on 23 May 2018 (the “Or­der”) (full text avail­able here). The Or­der rat­i­fies the OECD’s Mul­ti­lat­er­al Con­ven­tion to Im­ple­ment Tax Treaty Re­lated.
17/05/2018
Ar­ti­fi­cial In­tel­li­gence and Ro­bot­ics: From a La­bour and Tax Per­spect­ive...
Mod­ern in­form­a­tion tech­no­logy, in­tel­li­gent al­gorithms and pro­duc­tion ro­bots are strongly in­flu­en­cing the work­ing world in the 21st cen­tury. Every­day tasks are already be­ing per­formed by in­tel­li­gent al­gorithms.
23/03/2018
European Com­mis­sion con­firms pro­pos­als to tax the Di­git­al Eco­nomy
On 21 March 2018, the European Com­mis­sion an­nounced that it is mov­ing ahead with pro­pos­als to im­ple­ment both a Dir­ect­ive on di­git­al per­man­ent es­tab­lish­ment (“di­git­al PE”) and an in­ter­im tar­geted turnover tax (the press re­lease is avail­able here).
07/03/2018
Leaked doc­u­ment re­veals EU pro­pos­als for tax­ing the Di­git­al Eco­nomy
A leaked European Com­mis­sion doc­u­ment (dated 26 Feb­ru­ary 2018 and avail­able here) re­veals an in­sight in­to the EU’s in­ten­tions re­gard­ing tax­ing the di­git­al eco­nomy. The draft pro­pos­al notes there is a con­tinu­ing mis­match between where profits are taxed and value.
05/03/2018
EU pro­pos­als move ahead for a com­mon cor­por­ate tax base
The pro­posed Com­mon Cor­por­ate Tax Base (“CCTB”) and Com­mon EU Con­sol­id­ated Cor­por­ate Tax Base (“CCCTB”) have been ap­proved by the EU’s Eco­nom­ics and Mon­et­ary Com­mit­tee (an­nounce­ment here). The European Par­lia­ment’s brief­ing from Septem­ber 2017 is avail­able.
20/09/2017
Pub­lic Coun­try-by-Coun­try Re­port­ing; Tax­pay­er­s' Rights
Ap­pro­pri­ate Use of Coun­try-by-Coun­try Re­ports The OECD has now pub­lished Guid­ance (avail­able here) on the ap­pro­pri­ate use of Coun­try-by-Coun­try Re­ports (‘Cb­CRs’) by na­tion­al tax au­thor­it­ies. This is in re­sponse to some val­id MNE con­cerns that tax au­thor­it­ies.
16/03/2017
Im­pend­ing UK In­her­it­ance Tax Changes
In the 2015 Sum­mer Budget, pro­pos­als were an­nounced to change the UK tax re­gime for non-dom­i­ciles. These pro­pos­als were the sub­ject of a con­sulta­tion pa­per which was pub­lished on 19 Au­gust 2016. The new re­gime will take ef­fect as planned from 6 April 2017.
10/02/2017
In­dia Budget 2017 - 2018
On 1 Feb­ru­ary, Fin­ance Min­is­ter Ar­un Jait­ley presen­ted In­dia’s an­nu­al Uni­on Budget for 2017-2018 (the “Budget”) for the fisc­al year be­gin­ning 1 April 2017. The cent­ral aim in this year’s Budget ap­pears to fo­cus on the most vul­ner­able with in­creased spend­ing.