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By Emilien LEBAS, Partner, Head of International Tax, Tax controversy dispute resolution leader Sylvain RABOUINE, Senior Tax Adviser, International Tax, KPMG Luxembourg
On 21 April 2026, the Luxembourg Administrative Court of appeal (Cour administrative, 21 avril 2026, n°52991C) (the “Administrative Court” or the “Court”) took position on how an immovable property situated abroad and held via a tax transparent foreign entity, as well as debt in relation to its financing, should be treated for net wealth tax purposes.
In the case at hand, the controversy arose from the treatment, for Luxembourg net wealth tax purposes, of assets and liabilities relating to a Polish entity in which the taxpayer...
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