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Luxembourg: 2020 budget bill; expiry of tax rulings issued before 2015

Luxembourg: 2020 budget bill

The Luxembourg government on 14 October 2019 presented the 2020 draft budget law (bill 7500).


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The bill is subject to the legislative process and may be amended before its vote in the Chamber of Deputies.

The bill’s main tax measure relates to advance tax agreements issued before 1 January 2015. These agreements are no longer to be valid after the 2019 tax year. In 2015, the advance tax agreement procedure was updated and formalized in Luxembourg domestic law that limited the validity period of such agreements to five years. The bill’s new measure would provide for a transition between the old procedure and the new one.

KPMG observation

While advance tax agreements issued before 2015 may no longer be useful to many taxpayers—for example, due to a change in the law or to transactions that have stopped being effective—the new measure could still affect certain taxpayers that may request new agreements under the new procedure to cover subsequent tax years (from the 2020 tax year and onward).

Read an October 2019 report prepared by the KPMG member firm in Luxembourg

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