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Luxembourg: Tax procedure relief measures (COVID-19)

Luxembourg: Tax procedure relief measures (COVID-19)

The Luxembourg government has taken certain steps—including tax procedure relief measures—to support the economy in response to the coronavirus (COVID-19) pandemic.


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Prior guidance allowed:

  • Taxpayers to file a request online to cancel advance tax payments for the first and second quarter of 2020
  • Certain taxpayers to request a payment extension of four months without any late-payment interest
  • Taxpayers to extend the due dates for income and business tax compliance until 30 June 2020
  • Tax assessments to be appealed for a longer period of time (but also allowing the tax administration more time to implement enforcement measures if taxes are not paid in due time)

Read TaxNewsFlash

New measures adopted 7 May 2020 (Loi portant adaptation de certains délais en matière fiscale, financière et budgétaire dans le contexte de l’état de crise) provide additional tax procedure relief. This includes suspension of the deadlines for filing administrative appeals until 30 June 2020 (from 18 March 2020).

Taxpayers receiving a tax assessment, for example, as of 13 December 2019 now have until 1 July 2020 (instead of 18 March 2020) to file administrative appeals. As another example, tax assessments dated 13 January 2020 should have a new appeal deadline of 30 July 2020.

For tax assessments issued between 13 March and 25 June 2020, the three-month deadline is paused—it will begin to run on 1 July 2020 and end three months later, on 1 October 2020. If taxpayers missed deadlines for administrative appeals despite exercising all due care, they can still request a re-establishment of their rights.

Other measures reflect:

  • The tax relief also suspends or postpones the deadlines for bringing cases before the administrative tribunal or the court of first instance in direct tax matters.
  • The Luxembourg tax administration will have one additional year to assess, modify, collect and, if necessary, enforce direct taxes.
  • According to the new law, the statute of limitations period that would expire on 31 December 2020 will now be extended by one year to 31 December 2021.
  • Under the new law, any liens and mortgages that cease to be effective before 31 December 2020 are extended to 31 December 2021.

KPMG observation

Taxpayers may want to consider reviewing Luxembourg tax assessments that they may receive over the last five months, and note that they have more time to file administrative and judicial appeals against tax assessments (dated between 13 December 2019 and 25 June 2020) as well as taking into consideration the benefits and risks of entering into a tax dispute.

Read a May 2020 report prepared by the KPMG member firm in Luxembourg

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