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By Emilien LEBAS, Partner, Head of International Tax, Tax controversy dispute resolution leader Valentine PLATEAU, Manager, International Tax, KPMG Luxembourg
On 20 February 2024, the Luxembourg administrative court of appeal (“the Administrative Court” or “Court”) (Cour administrative, 20 février 2024, n°49388C) rendered a decision in which it took position on a taxpayer’s alleged economic ownership of some trademarks.
This decision concerns the appeal of joint cases issued during 2023(1) which we have already had the opportunity to analyze as part of our tax controversy series(2). While this appeal decision largely aligns with the position of the Luxembourg administrative tribunal (the “Administrative Tribunal” or “Tribunal”) –...
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