|
By Emilien LEBAS, Partner, International Tax, Tax controversy dispute resolution leader and Valentine PLATEAU, Assistant Manager, International Tax, KPMG Luxembourg
On 4 June 2024, the Luxembourg administrative court of appeal (“the Administrative Court” or “the Court”) (Cour administrative, 4 juin 2024, n°49203C) issued a decision in which it took a position on whether the partial liquidation carried out by the taxpayer (or “the claimant” or “the appellant”) through the redemption of classes of shares should be considered as abusive, and therefore requalified as a dividend distribution for tax purposes, i.e., subject to withholding tax (“WHT”) in Luxembourg.
The recent introduction of the bill of law n°8388(1) by the Luxembourg...
|