Luxembourg says ATAs issued before January 1, 2015 will be invalid after the 2019 tax year
Some Canadian multinational entities with operations in Luxembourg may be affected by a tax measure included in Luxemburg's 2020 budget bill that will soon invalidate certain advance tax agreements (ATAs). Specifically, ATAs issued by direct tax authorities prior to January 1, 2015 will no longer be valid after the 2019 tax year. Luxembourg's budget bill was published on October 14, 2019.
Notably, this particular tax measure is not unexpected. ATAs have been limited to a five-year term since new rules were formally introduced in domestic legislation, applicable for all ATAs filed on or after January 1, 2015.
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Information is current to October 29, 2019. The information contained in this publication is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavour to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act upon such information without appropriate professional advice after a thorough examination of the particular situation. For more information, contact KPMG's National Tax Centre at 416.777.8500