INTRODUCTION TO LUXEMBOURG TAX RULES FOR COMPANIES Thursday, March 21, 2019 - De 08h30 à 13h00

Delphine Deichtmann

This training deals with the key points of Luxembourg tax rules applicable to companies. The training will focus on a practical approach, including several case studies / tax calculations regarding corporate income tax (CIT), municipal business tax (MBT) and net wealth tax (NWT).

After this training, each participant should be able to:

• Calculate tax provisions for CIT/MBT/NWT, and particularly to understand the complex rules linked to NWT / minimum NWT,
• Fill out a tax return (form 500),
• Assess the tax credit for investment and fill out the corresponding tax form (form 800),
• Understand the participation exemption regime and fill out the corresponding tax form (form 506a),
• Understand how to deal with withholding tax issues in case of various shareholders types (individual / UE company / non-EU company) and fill out the corresponding tax form (form 900),
• Understand more complex aspects of the Luxembourg tax law (tax unity, hidden capital contribution, hidden distribution of dividends)

Direct tax

• Tax rules, taxable basis and rate of the corporate income tax (CIT), the municipal business tax (MBT) and the net wealth tax (NWT)
• Main tax adjustments of the taxable basis for CIT and MBT (deductions / recaptures)
• Detailed steps for the calculation of the NWT, including the calculation of the minimum NWT / reduced NWT and the rules related to the special five-year reserve for NWT
• Numerical examples for CIT, MBT, NWT calculation

Tax credit for investment

• Detailed calculation rules of the tax credit for investment
• User guide for tax form 800
• Numerical example for tax credit for investment

Tax losses carried forward

Participation exemption regime

• Conditions to apply the tax exemption of article 166 I.T.L. for dividends and capital gains
• Recapture rules applicable to charges economically linked to a shareholding (e.g. interest on the loan financing the purchase price of the shareholding)
• Rules to assess the financing of the shareholdings: historical approach or lump sum allocation
• Use guide for tax form 506A
• Numerical examples on deductible charges to recapture

Tax provisions calculation

• Numerical example of tax provision calculation for CIT, MBT and NWT, based on a real balance sheet

Tax return

• User guide for tax form 500
• Numerical example of tax return to be filled out based on a real balance sheet / to be linked with the tax provision calculation

Withholding tax

• Conditions to apply the withholding tax exemption for dividends of article 147 I.T.L.
• User guide for form 900 in case of various shareholders types (individual / UE company / non-EU company)
• Numerical example for various shareholders types

Other tax rules (advanced concepts)

• Tax unity
• Hidden capital contribution
• Hidden dividend distribution


Accountants, tax & legal advisors, CEOs & managers

Each participant will receive a written sample of the training

Thursday 21 March 2019
8.30 am – 8.45 am: Welcome & breakfast
8.45 am – 1 pm: Training

Price: EUR 400 VAT excluded

In case a participant would be missing without a 24 hours prior notice, the total amount of fees for the training will remain due to IF Group. Nevertheless, a participant from the same company / same group could replace the missing attendee, without prior notice.

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