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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 12 December 2024, the Luxembourg administrative Court of Appeal (Cour administrative, 12 décembre 2024, n°48677Cb et 48684Cb) (the “administrative Court” or the “Court”) ruled that the provisions of §177 (2) of the Luxembourg General Tax Law (Abgabenordnung, “AO”), were not compliant with EU law and notably article 7 and article 52 (1) of the Charter of Fundamental Rights of the European Union (the “Charter”) guaranteeing the confidentiality of legal advice given by lawyers.
Summary of the case
In the case at hand, the Luxembourg tax...
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