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Delphine Danhoui

Knowledge Lawyer | Avocat

Contact
CMS Luxembourg
Rue Charles Darwin 5
L-1433 Luxembourg
Luxembourg
Languages English, French

Delphine Danhoui is a knowledge lawyer in CMS Luxembourg Tax practice. She has more than 13 years of experience in Luxembourg advising clients on corporate tax and international tax planning in the context of cross-border transactions and reorganizations (e.g., mergers and acquisitions, corporate reorganizations and migrations). She has also experience assisting private clients in wealth tax planning and estate structuring.

She notably supports the team with research and by producing and managing knowhow resources.

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Expertise

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21/06/2024
New tax measures announced by the Luxembourg Prime Minister
On 11 June 2024, during his speech on the State of Nation, the Luxembourg Prime Minister Luc Frieden has announced a series of measures which include the following tax measures aiming to increase Luxembourg...
05/06/2024
CMS Expert Guide to Holding Company Regimes in Luxembourg
Specific holding company regime(s) SOPARFI stands for SOciété de PARticipations FInancières. A SOPARFI, which can take different corporate forms, is a fully taxable company benefiting from a broad...
Comparable
31/05/2024
Luxembourg Government proposes minor tweaks to tax rules following recent...
On 23 May 2024, the Luxembourg Government has submitted the tax bill 8388 for approval to the Luxembourg Chamber of deputies. The bill proposes amendments to certain tax provision (i) following developments...
26/01/2024
CMS Expert Guide to Mastering OECD's Pillar Two in Luxembourg
1. Has there been a formal indication of the intention to implement Pillar Two/GloBE rules? Yes. 2. What is the implementation status of Pillar Two/GloBE rules? 4 August 2023: in view of implementing...
Comparable
17/01/2024
Directors' fees are no longer subject to VAT in Luxembourg
On 21 December 2023, the Court of Justice of the European Union (“ CJEU ” or “ Court ”) issued a decision on the case C-288/22. The Court puts an end to a long debate by ruling that the members...
27/12/2023
No white smoke on ATAD III proposal in 2023
As a reminder, on 22 December 2021, the European Commission issued its proposal for a directive to prevent the abuse of shell entities for tax purposes (ATAD III proposal). After several amendments, the...
01/12/2023
Un­con­sti­tu­tion­al­ity of the minimum net wealth tax of EUR 4,815
Un­con­sti­tu­tion­al­ity of the minimum net wealth tax of EUR 4,815On November 10, 2023, the Luxembourg Constitutional Court ruled that the minimum net wealth tax (NWT) of EUR 4,815 as provided for by paragraph...
27/09/2023
DAC 8 Proposal approved by the European Parliament
BackgroundIn recent years, the crypto-asset landscape has steadily grown and has reshaped the world of payments and investments. Today such assets have an estimated market capitalization of USD 1.09 trillion...
04/08/2023
CMS Expert Guide on substance issues across Europe
The focus on entity substance in the context of investment structures has sharpened significantly in recent years. Holding companies involved in cross-border transactions must have sufficient economic...
Comparable
20/07/2023
Luxembourg court emphasizes need to justify and document economic reasons...
On 14 June 2023, the lower administrative court rendered a new decision (case n° 45759) once again dealing with the tax treatment applicable to the redemption by a Luxembourg company of so-called “alphabet...
13/02/2023
Lower administrative court’s decision on redemption of a class of alphabet...
On 27 January 2023, the lower administrative court rendered a decision (42432) dealing among others with the tax treatment applicable to the redemption of a class of alphabet shares. Under Luxembourg...
01/02/2023
Clarifications on the Luxembourg reverse hybrid mismatch rule
BackgroundOn 23 December 2022, the Luxembourg Parliament adopted bill n°8080 related to the budget for 2023 (the "Budget Law 2023" – see our newsflash on the budget bill here), which contains, among...