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By Emilien LEBAS and Valentine PLATEAU, KPMG Luxembourg*
On 26 July 2023, the Luxembourg administrative court of first instance (Tribunal administratif) confirmed the decision of the director of the Luxembourg tax authorities (Administration des contributions directes – LTA) to deny a company eligibility to the intellectual property (IP) exemption regime regarding some trademarks, on the grounds that it could not be regarded as the owner of the trademarks in question (Trib. administratif, 26 juillet 2023, n° 45706 et n°46555).
In this second article of our tax controversy series, we will focus on what the key focus of this judgment is for us: economic appreciation and ownership.
Summary of the facts...
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