Corporate Income Taxation

Reduction of Corporate Income Tax Rates
The standard corporate income tax rate for companies located in Luxembourg City has been reduced, decreasing from 24.94% to 23.87%.

Interest Deductibility Rules for Borrowing Costs in Securitisation Vehicles
Amendments have been made to the deductibility of borrowing costs, introducing the concept of a Single Entity Group (SEG). Securitisation vehicles financed through third-party debt may qualify as SEG under specific conditions, enabling them to deduct all exceeding borrowing costs. A careful assessment of these new provisions is advised on a case-by-case basis.

Clarifications on the Share Buyback Regime
New legal provisions outline the criteria under which redeeming and cancelling an entire class of shares (or corporate units) is treated as a partial liquidation. This process, not subject to Luxembourg withholding tax, offers increased clarity and legal certainty for businesses.

Optional Tax Exemptions for Dividends and Capital Gains
Taxpayers can now elect annually to opt out of tax exemptions for dividends and capital gains, a choice that may prove beneficial in cases where tax losses carried forward are available.

 

Other Tax Measures

Subscription Tax Exemption for Actively Managed ETFs
Actively managed exchange-traded funds (ETFs) have been made exempt from the subscription tax.

Reduction in Real Estate Registration and Transcription Duties
Real estate acquisitions between October 1, 2024, and June 30, 2025, will benefit from a 50% reduction in the taxable base for registration and transcription duties.

Simplified Minimum Net Wealth Tax Structure
The revised minimum net wealth tax (NWT) rates now depend on the total balance sheet value:

  • €535 for total assets up to €350,000
  • €1,605 for total assets between €350,000 and €2 million
  • €4,815 for total assets exceeding €2 million

 

Updates to the impatriate tax regime

Luxembourg has introduced a revised impatriate tax regime effective from January 1, 2025, aimed at attracting highly skilled professionals to the country. The key features of this regime include:

  • 50% Tax Exemption: Eligible impatriate employees can benefit from a 50% exemption on their gross annual remuneration, including benefits in kind, up to a cap of €400,000.
  • Duration: This tax benefit is available for a period of eight years.
  • Eligibility Criteria:
  • Prior Non-Residency: The impatriate must not have been a tax resident in Luxembourg or have lived within 150 km of the Luxembourg border in the five years preceding their employment.
  • Minimum Salary: A gross annual salary of at least €75,000 is required.
  • Employment Proportion: The professional activity in Luxembourg should represent at least 75% of their working time.
  • Employee Cap: No more than 30% of the company’s workforce can benefit from the impatriate regime.
  • Individuals currently benefiting from the existing impatriate regime can choose to opt into the new regime starting in 2025; however, this choice is irrevocable.

These measures are part of Luxembourg’s strategy to enhance its attractiveness to international talent by offering competitive tax incentives.

If you are interested to know more about how the new tax benefits might benefit you, please contact Fabio Mastrosimone at f.mastrosimone@umawealth.com