The Luxembourg interest limitation rule: article 168bis LIR in practice
Luxembourg interest limitation rule under article 168bis LIR: 30% EBITDA cap, €3 million de minimis, grandfathered loans, equity escape, carry-forwards and fiscal unity.
Tax
12 articles in this category
Luxembourg intragroup financing: transfer pricing for HoldCos and SPVs
Luxembourg intragroup financing and transfer pricing for HoldCos and SPVs: functions, risks, arm’s-length interest, documentation, substance and annual review.
Dividends in Luxembourg: withholding tax, exemptions and optimisation
Dividends in Luxembourg: 15 % withholding tax, parent-subsidiary exemption, treaty rates, resident and non-resident treatment, optimisation via SOPARFI.
Tax Consolidation in Luxembourg: Conditions, Benefits & Implications for Group Companies
Tax consolidation in Luxembourg: Article 164bis LIR conditions, 95 % participation threshold, loss offsetting, 5-year commitment, wealth tax exclusion.
VAT in Luxembourg: rates, obligations and returns
VAT in Luxembourg: applicable rates (17 %, 14 %, 8 %, 3 %), filing obligations, special regimes, intra-Community supplies and penalties.
SOPARFI's tax regime, the Luxembourg holding
SOPARFI in Luxembourg: taxation, obligations, advantages and points of attention for holding and participation structures.
Carried interest taxation in Luxembourg: the regime in force from January 2026
Carried interest taxation in Luxembourg from 2026: contractual carry at a quarter of the global rate, participation-linked carry and eligibility rules.
Reverse hybrid rules and the Luxembourg SCSp: Article 168quater LIR after the 2025 circular
Reverse hybrid rules for the Luxembourg SCSp under Article 168quater LIR: 50% associated-investor test, CIV carve-out and the August 2025 circular.
SPF in Luxembourg: tax regime, restrictions and when it fits
SPF in Luxembourg: private-wealth perimeter, eligible financial assets, subscription tax, treaty limits and the cases where a SOPARFI fits better.
Real Estate Capital Gains in Luxembourg: calculation, exemptions and tax
Real estate capital gains taxation in Luxembourg: tax rates, possible exemptions and tax planning points when selling property.
Embassy Employees in Luxembourg: Tax & Social Security (Including Dual Nationals)
Embassy employees in Luxembourg: tax exemption under the Vienna Convention, taxable local staff, CCSS affiliation and EU 883/2004 social security rules.
SCI in Luxembourg: tax transparency, partners and real estate
Understanding the SCI in Luxembourg: tax transparency, partner liability, real estate capital gains and registration duties.