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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 6 August 2025, the Luxembourg Administrative Court of Appeal (Cour Administrative, 6 août 2025, n°52321C) (the “Administrative Court” or the “Court”) clarified implications deriving from a provisional tax assessment issued under § 100a of the General Tax Law (Abgabenordnung, “AO”) and confirmed that tax offices have full discretion to decide whether to revisit a tax assessment at a later point in time.
In this context, the most interesting question raised in this decision is probably the following: when a provisional tax assessment has been issued based on a return...
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