CA CA, Sébastien Labbé, Sébastien Labbé, Flora Castellani
Over the past few years the OECD, the European Commission and governments have regularly issued new requirements and corresponding implementation guidelines to enhance fair tax competition and increased fiscal transparency.
Luxembourg, like any other developed country, has been supporting those actions and introduced, or is planning to introduce measures towards compliance with these new international standards.
While Luxembourg is adapting its tax framework to these changes, it also aims to keep its level of attractiveness. Thus, one of the measures recently announced by the government to remain competitive is the progressive decrease of the corporate income tax rate from 21% to 18% (leading to a global income tax rate of circa 26% in 2018). Other tax measures to maintain Luxembourg's tax competitiveness for corporate entities could be announced in the near future.
As a first step towards compliance with the nexus approach, as recommended by the OECD for IP regimes in the BEPS Action 5 report (issued on October 5 2015), the Luxembourg legislator abolished the provisions on IP regimes as from July 2016 with a grandfathering period until June 2021. Tax transparency is reinforced by the requirement to a spontaneous exchange of information by the Luxembourg tax authorities on the identity of taxpayers that benefited from the regime since February 6 2015.
The release of a new IP regime in line with the nexus approach is expected in the coming months.
The amended EU Parent-Subsidiary Directive (the Directive) has been transposed into Luxembourg domestic tax law by introducing two additional provisions. That is, a general anti-abuse rule and an anti-hybrid mismatch rule. As a result, since January 1 2016, profit distributions falling within the scope of the Directive can no longer be tax exempt in Luxembourg if such distributions are deductible by the payer located in another EU member state, or if the transaction is characterised as abusive (ie not "genuine") within the meaning of the Directive. Similarly, dividends paid to EU companies may also be subject to withholding tax if the transaction is considered as abusive.
Following a strict transposition of the Directive, the new rules do not apply to dividend distributions to/from non-EU companies and/or not covered by the Directive, nor to capital gains or net worth tax.
Luxembourg transposed into national law in December 2015 the Council Directive 2014/107/UE of 9 December 2014 amending Directive 2011/16/EU as regards mandatory automatic exchange of information in the field of taxation, according to which the member states will require their financial institutions to implement reporting and due diligence rules. In Luxembourg, the first exchange of information will take place from 2017, based on financial information collected in 2016.
Luxembourg also transposed into national law the Directive adopted by the EU Council in December 2015, related to the exchange of information on cross-border tax rulings and advance pricing agreements. The law foresees the automatic exchange of said information to the tax authorities of the EU member states and to the European Commission, from January 2017.
In May 2016, the European Council adopted a Directive which introduces country-by-country (CbC) reporting following the recommendations made by the OECD under BEPS Action 13. The obligation of preparing a CbC report will apply to very large multinational groups for which the total consolidated group revenue exceeds €750 million ($835 million). The relevant reporting entity will have to submit certain information to the tax authorities of its residence member state (including inter alia turnover, pre-tax profit, income tax paid and accrued, number of employees) on an annual basis and for each tax jurisdiction where the group does business. The member state of residence would then have to automatically exchange data with the other relevant member states. The obligation to prepare a CbC report will apply for the fiscal year commencing on or after January 1 2016, subject to exceptions.
Luxembourg is expected to issue a Bill transposing the above provisions into Luxembourg domestic law in the coming months.
In order to comply with EU law, the Luxembourg legislator introduced the following measures at the end of December 2015.
From January 2015, the (vertical) tax unity regime has been extended to tax groups formed by sister companies without their (foreign or domestic) parent company being part of the tax unity.
From January 2016, the minimum corporate income tax (CIT) has been replaced by a minimum net wealth tax (NWT) under similar conditions, with some exceptions. The new minimum NWT is computed on a very similar basis as the previous minimum CIT and ranges from €535 to €32,100.
The law also introduced a digressive NWT rate where the net taxable wealth of corporate taxpayers exceeds a certain threshold. Thus, the NWT rate is reduced to 0.05% for the part of the unitary value exceeding €500 million, whereas the part of the unitary value equal or below €500 million remains taxable at the current rate of 0.5%.
At the end of December 2015, Luxembourg introduced a step-up system for individuals transferring their tax residency to Luxembourg, which was retroactively effective from January 1 2015. In such a case, the acquisition price of shares and convertible loans held by the taxpayers holding substantial shareholdings (ie participations of more than 10%) will be deemed to be the estimated realisation value of the said assets at the date when the individual becomes a Luxembourg resident taxpayer. The initial acquisition date of the assets transferred is still to be considered when calculating the holding period. Consequently, these taxpayers will not be taxed in Luxembourg on the latent capital gains existing on these assets prior to their transfer of residence.
In order to comply with EU principles, the legislator also introduced an option for all individuals who were not tax residents in Luxembourg for the entire year to be taxed in Luxembourg as if they had been residents for the whole year. This was introduced at the end of December 2015, to be effective as of January 1 2015. This option aims at granting the possibility for these taxpayers to benefit from full year's tax rates, exemptions, and tax deductions/credits. An option already existed, but was limited to employees and retired persons who were tax resident for only part of the year.
Luxembourg has introduced a temporary tax amnesty regime for the years 2016 and 2017 for the benefit of both resident and non-resident taxpayers. To benefit from this tax amnesty, Luxembourg taxpayers will have to spontaneously file an amended tax return and pay the tax due plus a penalty of 10% if reported in 2016, or of 20% if reported in 2017.
In June 2016, Luxembourg passed a law on the reduction of tax rate on gains realized from the disposal of certain real estate assets owned by private individuals with effect from July 1 2016.
Under the previous rules, capital gains (net income) in relation to the sale of real estate, being a secondary home or investment land/property (ie not the taxpayer's main residence) and held by the taxpayer for more than 2 years were taxed at ½ of the taxpayer's global tax rate as extraordinary income. For a limited period of time, from July 1 2016 to December 31 2017 (inclusive), the taxation of such gains realised during this period will be reduced to ¼ of the global tax rate of the taxpayer.
The Luxembourg authorities confirmed in early 2016 that directors' fees will be subject to VAT at the standard VAT rate of 17%. As directors have to be considered as taxable persons for VAT purposes, their remuneration should be subject to VAT. The VAT exemption of fees paid to directors of Luxembourg investment funds may apply, however this has to be determined on a case-by-case basis. Directors have until January 1 2017 to comply with this new rule.
The Luxembourg government has been working on a comprehensive tax reform to be implemented from January 2017.
Facing the challenge of maintaining Luxembourg's tax competitiveness, the government reaffirmed that the developments in the international tax landscape and in particular the transposition of the BEPS measures at the European level will be closely followed. The objective is to adapt the Luxembourg tax framework to these changes in order to ensure that it remains attractive while respecting the new international and European standards, in the spirit of a level playing field.
One the most significant measure for competitiveness is the expected decrease of the corporate income tax rate. It would fall from its current rate of 21% down to 19% in 2017, and to 18% in 2018, thus leading to a global tax rate of 27.08% in 2017 and 26.01% in 2018 (for companies in Luxembourg City). Moreover, the corporate income tax rate would decrease from 20% to 15% for corporations with a taxable basis up to €25,000 in favor of start-ups and small enterprises. The minimum net wealth tax for holding companies would however be increased from €3,210 to €4,815.
In addition, the government announced the creation of specialised working groups to address various key topics for the competitiveness of the country, such as the development of start-ups and more generally of small and medium-sized enterprises (SMEs), as well as the introduction of a regime for an immunised reserve for investment.
To stimulate corporate investments in Luxembourg, in particular in the innovation sector, the government also proposed a one percentage point increase in investment tax credit rates.
Finally, the government announced some limitations to the right to carry tax losses forward. Tax losses incurred from tax year 2017 would only be offset against 75% of the annual taxable profit realised in future years and the carry-forward period would be limited to 17 years.
With respect to individuals, several measures have been announced, including the restructuring of the current tax rate scales, the increase of tax credits (ie tax credits for employees, pensioners, and single-parent families), the increase of the marginal tax rate on upper income taxpayers to 41% for annual income of more than €150,000 and to 42% for annual income higher than €200,000 (for taxpayers in tax class 1), and the increase of the final withholding tax rate on in-scope interest paid out to Luxembourg resident individuals.
The Bill is expected to be released in Autumn 2016. One should consider that changes to the above announcements cannot be excluded.
Going forward, Luxembourg will have to further adapt its legislation to the constant international and EU developments. The next step will in particular be the transposition of the Anti-Tax Avoidance Directive (formally adopted by the EU Council in July 2016) before 2019. This Directive introduces measures from the BEPS package (ie BEPS Actions 2, 3 and 4) and other additional anti-abuse measures (ie general anti-abuse rule and exit taxation rule).
It has been a busy year for tax in Luxembourg as the authorities are challenging multinationals' structures more thoroughly. In addition, the country's attractive tax ruling process has been under review by the government. The tax market in Luxembourg is experiencing a number of changes following the LuxLeaks scandal that unearthed rulings agreed between multinational companies and the tax authorities. This is causing uncertainty among taxpayers, and many are considering plan B.
"One of the main trends has been that it is much more difficult to provide tax advice because we are in a grey area where we cannot predict the future relationship with the tax authorities," said Christoph Clément, head of tax at Clément & Avocats. "The new ruling process has been clarified a bit more now as to what will be accepted practice."
Taxpayers are thinking about the future of their structures and are more cautious than they were in the past. Luxembourg is becoming more and more transparent so the various structures need to be robust and justifiable.
The international focus on anti-avoidance has also impacted the Luxembourg tax landscape, particularly through the OECD's BEPS Project and the EU's Anti-Avoidance Directive, which was agreed on June 16 2016. "The main thing on a technical level for clients has been the discussions in Europe and in Brussels on the Anti-Tax Avoidance Directive because that will basically impact every Luxembourg structure there is," said Peter Adriaansen of Loyens & Loeff,
Although BEPS has been a hot topic in most jurisdictions, little has been implemented in Luxembourg. Taxpayers have been preparing for the potential BEPS implementations and changes nonetheless, and tax advisers report that they are being asked to do a lot of substance reviews for taxpayers to ensure they are compliant in the new tax world both internationally and in Luxembourg.
Although the authorities are struggling to keep up with the changing tax environment and lacking resources, advisers report that they remain focused on making sure that things are done properly.
"The authorities are doing their job in the interest of Luxembourg. This does not, however, mean that they see the taxpayer as an enemy," said Andre Pesch, head of tax at Baker & McKenzie. "The authorities make certain that the tax law is being respected. Luxembourg taxpayers and authorities have learned that having a relationship of mutual respect and transparency is by far more efficient than the hide and seek and wargames to which one may expect in some countries."
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Arendt & Medernach is the leading independent business law firm in Luxembourg. It is also Luxembourg's largest law firm with an international team of more than 285 legal professionals representing Luxembourg and foreign clients in all areas of Luxembourg business law from our head office in Luxembourg and our foreign offices in Dubai, Hong Kong, London, Moscow, New York and Paris.
We have a tax team of around 40 experts, with dedicated VAT, transfer pricing and tax compliance teams, who provide bespoke tax advice and assistance to international and Luxembourg clients including fund promoters, managers and investors, banks and insurance/reinsurance companies, MNCs as well as HNWI in numerous areas including fund formation, private equity, real estate, M&A and financing transactions as well as wealth planning.
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Loyens & Loeff is an independent full service law firm, specialised in integrated legal and tax advice. We have a 100-year track record of international (corporate) tax planning with more than 350 top tax specialists, international tax lawyers and 500 corporate/regulatory lawyers working from our offices in all major financial centres.
We understand that multinational businesses and cross border investors are increasingly faced with a multitude of international developments that impact their decision making, raising questions about how to structure future projects and transactions. In these complex, constantly evolving situations, we offer pragmatic advice and tailor-made solutions.
Our Tax practice covers all areas of tax law and is integrated with our other practices such as Corporate M&A, Real Estate, Investment Management/Funds, Private Equity, Banking & Finance, Capital Markets, Private Client, Employment, Commercial Litigation and Energy.
Areas of tax include tax optimisation, tax compliance, transfer pricing, tax assurance, estate planning, employment tax, European tax, accounting standards and financial reporting, financing and venture capital, holding structures, international and national tax planning, corporate restructuring, rulings, tax litigation, VAT, customs and excess, and international trade.
|Corporate Income Tax||21%||A|
|Capital Gains Tax||21%||A|
|Net Operating Losses (years)|
|Royalties from, for example, patents, know-how||0%|
A This is the maximum rate. A municipal business tax and an additional employment fund contribution (employment fund surcharge) are also levied on income. A new minimum tax regime is effective from January 1 2013.
B A 15% dividend withholding tax is imposed on payments to resident and non-residents. Under Luxembourg domestic law, a full withholding tax exemption applies to dividends if they are paid to qualifying entities established in EU/EEA member states, Switzerland or a country with which Luxembourg has entered into a double tax treaty and if certain conditions are met.
Jean Schaffner heads the tax practice at Allen & Overy in Luxembourg, leading a team of dedicated tax specialists. The firm offers a full range of services including tax structuring, compliance services, private equity transactions and M&A. Schaffner specialises in advising international investment banks on structured finance schemes and he has extensive experience advising institutional investors and private equity funds in cross-border transactions. He works closely with partner Patrick Mischo who specialises in international and corporate tax law. He advises clients on the tax aspects of private equity transactions and international real estate investments, as well as the structuring of regulated and unregulated investment funds.
Arendt & Medernach's tax team is led by head of tax Thierry Lesage, and supervised by four other partners Eric Fort, Alain Goebel, Bruno Gasparotte and recently appointed partner Jan Neugebaur. They are supported by 30 other professionals working across the private equity, real estate, investment management and banking industries.
The team provides tailor-made tax advice and innovative solutions and develops tax-efficient structures for corporate and finance transactions. It offers a full scope of services ranging from VAT registration to filing tax returns, as well as assisting clients in disputes and in the verification of data reporting.
Lesage advises on both national and international tax issues and focuses on private equity, real estate and finance transactions. He and his team are currently representing a leading US multinational group in an appeal procedure against tax assessments imposing Luxembourg corporate income tax and municipal business tax of approximately €35 million ($39 million) onto its Luxembourg subsidiary.
The team came highly recommended by clients for its quality of work with one client saying it stands out from the crowd. Another said the firm was a "top notch firm, responsive, proactive and solution oriented".
ATOZ, Taxand Luxembourg's tax practice is headed by managing partner Keith O'Donnell. He is the head of Taxand's global real estate team and has more than 20 years of experience. The independent tax firm comprises 15 partners and 57 professionals and is integrated within the global network.
It offers a wide range of tax and financial advisory services and has, since its inception in 2004, continued to provide quality services to its clients from the private equity, real estate, corporate and financial sectors with technical skill and project management expertise.
The firm advised on the funding and execution of a major North American acquisition this year, involving the use of an innovative Luxembourg financing structure in order to preserve the seniority of different financiers, while allowing for the deduction of the financing costs from multiple sources valued at over $10 billion.
Baker & McKenzie is recognised by its peers and clients as one of the strongest tax teams in Luxembourg. The tax practice boasts a robust and stable team with senior experience and many professionals that have previously worked at Big 4 firms. The team has broad expertise and offers a range of services including consulting and compliance, as well as staple work within corporate tax, asset management and banking and finance.
The practice leader is André Pesch who has been practicing in the country since 1993 and has a wealth of expertise in advising on Luxembourg tax issues related to tax efficient investment, holdings, financing and intellectual property (IP) structures. He advises many multinationals, financial institutions and asset managers and is often engaged in the tax analysis of capital market transactions and the development of structured products.
This year, six new professionals joined the team, including Antonio Weffer, head of transfer pricing, Carlos Morales Ribas, Nicolas Jeangeorges and Candido Duarte. The team now comprises three partners and 10 professionals.
The firm was praised by clients. One said the tax advisers provided prompt feed-back and strong technical analysis. They said: "André is very pragmatic and a very quick and smart thinker. He has a very large experience and is able to provide very efficient solutions. He is also able to suggest alternatives which is really a great quality."
The international law firm Bonn & Schmitt has a strong focus on international corporate tax and devotes most of its efforts to advising multinationals, funds and financial institutions throughout Europe, Asia, the US, South America and South Africa. The service offering includes indirect and VAT services and the team has strong emphasis on tax litigation and are active in multi-jurisdictional private equity cases.
Members of the tax team include associates Pierre-Luc Wolff, Patrick Andersson and Katharina Schiffmann, senior associate Anne Selbert, and counsel Gaëlle Felly.
Alain Steichen leads the tax practice at Bonn Steichen & Partners supported by two other partners, one principal and seven professionals. Steichen has extensive experience in banking and financial services as well as private equity, M&A, and private wealth and business planning. The firm's tax offerings include disposals, acquisitions and joint ventures, tax audits and litigation, planning, VAT, investment vehicles, transfer pricing and structured finance. Partner Jean Steffen specialises in tax and private equity which enables the firm to advise major private equity clients. Another significant member of the team is Christine Beernaerts who is a highly specialised tax principal with an economics background.
Clément & Avocats was founded in 2014 by tax partner Christoph Clément. The team now consists of two partners and three professionals. Prior to founding the firm, Clément was a tax partner at Baker & McKenzie and has worked at Clifford Chance, PwC and Andersen. "Ultimately I am a tax partner, a tax specialist, so that's really the DNA of the firm and all the clients are dealing with international tax," said Clément.
Clément has more than 15 years' experience in advising on debt funds, private equity and real estate funds, structured finance, securitisation and debt restructuring. He focuses on M&A, company reorganisations, IP and incentive plans.
Partner Jens Konrad joined the firm in 2015 and focuses on tax litigation. Olympa Alexandra focuses on direct and indirect tax and Lado Rigvava specialises in direct tax. Theodore Fisher is an attorney advising in the areas of banking and finance and capital markets, investment funds, corporate and regulatory law.
François-Xavier Dujardin oversees the tax practice at Clifford Chance in Luxembourg. He has more than 17 years of experience as a tax expert and specialises in funds, structured finance and international tax structuring. The team of professionals provides the full scope of tax services, working closely with other international Clifford Chance offices.
It has particular expertise within cross-border taxation advice, as well as across the spectrum of international and domestic tax issues such as banking and finance, capital markets and structured debt, M&A and joint ventures tax.
Raymond Krawczykowski is the head of tax at Deloitte. It is one of the biggest tax groups in the country with 31 partners and 376 professionals. The full-service firm combines insight and innovation from multiple disciplines, with business and industry knowledge to meet client's demands. It offers individual taxation and global mobility planning, as well as advisory services for multinationals, financial institutions and medium-sized domestic enterprises. The financial sector is a key area for the firm and the services within the area include compliance, tax reclaims and private banking.
A client said they would recommend the firm "for their proactivity and reactiveness on our tax matters, the innovation, synergies and structure that can cover our group presence and needs in various jurisdictions, and the flexibility of the entire team in Luxembourg and especially of our dedicated liaison/account manager".
The Luxembourg office is well-integrated into the global network, collaborating frequently across the worldwide team.
Frédéric Feyten is the managing partner and head of tax at Dentons' Luxembourg office. He focuses on domestic and international tax, M&A, financial products and structured finance. The tax team advises on a range of business tax issues related to direct tax and indirect tax, VAT, cross-border transactions, M&A, structured finance and domestic investment funds.
The majority of the firm's consultancy work and tax advice covers tax structuring and international planning for multinational corporates, private equity and other investment funds related to M&A, holding, finance and IP activities and structured finance and financial products. The team also assists clients on VAT and other indirect tax matters including compliance and structuring, negotiation and filing advance tax agreements with the tax authorities.
As of January 2016 the firm, formerly OPF partners, joined the global law firm Dentons.
DLA Piper's head of tax Geoffrey Scardoni leads the team of five professionals in Luxembourg. The practice was established in 2014 but has grown with three new hires this year. Bernard Morlet, joined from KPMG and has experience as a tax adviser with emphasis on structuring and transfer pricing. Danara Ungunova, who has experience as a lawyer focusing on tax structuring and transactional tax, and has previously worked for Deloitte, Clifford Chance and KPMG, and Aleksandra Rychel, a VAT and fund expert from Deloitte.
The team has expertise in the alternative fund industry including private equity, real estate and fund formation. It also covers direct tax, VAT, transfer pricing and structuring and has knowledge of most foreign tax aspects surrounding fund structuring and acquisitions.
Despite its size, the team has worked on various impressive projects this year. One included advising a major US and Canadian pharmaceutical company with regards to the Luxembourg aspects of cross-border mergers. The firm comes recommended and a client described it as a great team and very good service.
Elvinger Hoss Prussen was established in 1964 as an independent business law firm. The three founding partners work in the tax practice, André Elvinger's specialism is corporate and pure tax and is an honorary president of the Luxembourg Association for Fiscal Studies. Jean Hoss focuses on the banking, commercial, financial and corporate tax law aspects. Yves Prussen is also specialised in tax law and is active in property law and real estate litigation.
The team of 246 professionals, including 29 partners at EY offers a complete range of tax services including international tax structuring, corporate and international tax advice, transfer pricing and advice on operational model effectiveness, tax reporting, accounting and compliance services and assisting high net worth individuals in all tax matters.
Marc Schmitz leads the team, which is one of Luxembourg's largest tax practices, and specialises in restructuring, international tax, cross-border transactions and general tax advisory for a diverse portfolio of clients. Schmitz and his team worked on one of the largest merger transactions in the healthcare industry this year, advising on various complex Luxembourg corporate tax matters related to the multibillion merger.
The firm has appointed five new partners for the next year, Christian Schlesser, Vincent Remy, Sylvie Leick, Adriana Boixados Prio and Fernando Longares.
Clients said the firm has excellent technical knowledge, business acumen and a hands-on approach and praised Estelle Collardeau. Overall, clients said EY was a good alternative to law firms.
Frédéric Dupont heads the team of three other professionals at Jeantet. The compact team assists clients on corporate and asset taxation including tax consolidation, VAT and tax audits. Due to its size, the team is able to work quicker and offers tailor-made services dealing with complex, tax-driven transactions. The firm also offers expertise in structured finance and wealth restructuring and covers all the main aspects of tax.
Paul Potocki is a tax counsel who joined in 2014, Armand Guigma joined in 2014 and is a senior associate, and Rhossoune Bouselsal is an associate and joined in May 2015. Dupont has more than 14 years of experience in tax consultancy and is specialised in the area of investment funds, capital market structures and structured financing.
KPMG's tax department is among the largest accounting firms in the country and includes a corporate business tax practice, a financial services team, indirect and international tax, people services and accounting advisory services. The tax team is headed by Sébastien Labbe who has more than 20 years' experience in the financial sector and provides ongoing tax advice to groups active in this sector, as well as specialising in corporate taxes in the banking, insurance and investment funds sectors.
This year, the team advised a number of European financial institutions on the financing of movable assets via structures leases, including tax advice and the review of financial models.
Clients described KPMG Luxembourg as pleasant to deal with and very responsive. One client said: "I recommend this firm for its knowledge and for its important network to cover tax matters over the world."
The team comprises 26 partners and 263 professionals, including 77 new hires this year. The financial services team is led by Gérard Laures with support from Laurent Engel and Frank Stoltz. The international tax team is led by Louis Thomas, supported by Sophie Smons and Basien Voisin, while Pierre Kreemer leads the alternative investments team working closely with Antoine Badot, Julien Bieber and Giuliano Bidoli.
Olivier Van Ermengem is a tax partner at Linklaters and leader of the tax practice. He advises multinational companies on corporate, investment and international tax associated with cross-border investments. He has particular knowledge of the tax structuring of investment in the venture capital, private equity and real estate sectors, as well as transfer pricing and tax litigation.
Loyens & Loeff is an international law firm based in the Benelux region and Switzerland, comprising 44 partners and 300 professionals. Pieter Stalman leads the tax team in Luxembourg which offers a full suite of services. The team is specialised in the Luxembourg corporate and tax law of international structures, IP, financial products, holding structures, investment platforms and corporate reorganisations. Alongside advising on daily tax optimisation, advance tax rulings and transfer pricing negotiations, VAT, compliance and second opinions, the firm also assists clients with state aid analysis of tax matters.
Loyens & Loeff has the knowledge and experience to assist clients in negotiations with the authorities and provide litigation services in all areas of tax. Stalman specialises in advising multinational clients on cross-border transactions and group restructuring, particularly for the Benelux countries, Japan, China and Switzerland.
This year, the team advised on the VAT optimisation of the acquisition of an immovable property located in Luxembourg. The advice concerned all the indirect tax aspects of the transactions contemplated. The acquisition of the building and the contemplated activities of hotel apartments, office and retail services have been structured with the view to reduce the VAT leakage as much as possible.
The Luxembourg branch of NautaDutilh is co-headed by Jean-Marc Groelly and Christophe Joosen. Groelly specialises in international tax law with emphasis on the tax aspects of investment funds, private equity, and real estate, M&A and structured finance transactions. He advises clients on tax planning and provides tax advice to high net worth individuals. Joosen is specialised in international tax law and works extensively in the structuring of real estate, investment funds, capital markets and structured finance transactions. He also assists multinational groups across various industries with their international tax planning. The full-service firm focuses on its client portfolio of large multinationals and financial institutions.
Wim Piot leads the tax practice at PwC and specialises in real estate funds, the financial sector as well as Islamic finance. The tax team advises businesses, individuals and organisations with tax strategies, planning and compliance services. It also offers a wide range of additional tax services including corporate and indirect tax, IP, international structuring, M&A, controversy and dispute resolutions, transfer pricing and tax research.
The accounting firm is part of the global PwC network which operates from more than 140 countries and comprises 30,000 tax specialists.
Stibbe has a full-service tax practice operating across the Benelux region. Its practice areas include corporate tax, incentives, tax planning, tax controversy and VAT and other indirect taxes. The team also advises on many domestic and international matters including M&A, private equity, finance structures, capital markets, securitisations, EU Law and tax treaties, public-private partnerships, project finance, restructurings and real estate.
Van Campen Liem is a boutique firm focusing on private equity, tax and M&A. The Luxembourg tax team is led by Raffaele Gargiulo, an Italian tax adviser with experience from PwC Luxembourg and EY New York. He specialises in structuring cross-border investment for private equity and hedge funds and has extensive experience assisting US, Canadian and UK clients. The Luxembourg team comprises two partners and two other professionals, including new hire Eduardo Trancho who joined the firm in March from ATOZ, Taxand Luxembourg.
The firm was highly recommended by clients. One client said: "Our main contact, Marcello Distaso, is a manager type of lawyer. Proactive and structured. Andrew de Vries is executing most of our projects. He thinks conceptually and is very reliable. Basically he gets things done the way, and in the time, you want them to be done."
Van Campen Liem was founded in 2012 by former Baker & McKenzie partners in Amsterdam. The firm opened an office in Luxembourg in 2013, combining Dutch and Luxembourg tax capabilities which makes it a key player in tax planning for cross-border deals.
|Tier 1- Luxembourg|
|Allen & Overy|
|Arendt & Medernach|
|Baker & McKenzie|
|Loyens & Loeff|
|Tier 2- Luxembourg|
|ATOZ, Taxand Luxembourg|
|Bonn Steichen & Partners|
|Tier 3- Luxembourg|
|Bonn & Schmitt|
|Elvinger Hoss Prussen|
|Tier 4- Luxembourg|
|Van Campen Liem|
|Firms to watch-Luxembourg|
|Clément & Avocats|