Commerce & Industry

Our tax teams collaborate with our deal advisory colleagues to assist you with corporate reorganizations (e.g., mergers, acquisitions, joint ventures, sales). Our tax services include:

• Tax due diligence services (buy and sell side)
• Structuring advice
• Post-acquisition integration advice
• Streamlining value chain services (in collaboration with our transfer pricing team)

Our experts support multinational and smaller businesses with their tax strategies and offer a broad range of advisory services, such as:

• Corporate restructuring, intra-group financing, cash pooling, IP, leasing activities, entity rationalization, etc.
• Luxembourg participation exemption analysis
• Transparency/opacity analysis of foreign entities for Luxembourg direct tax purposes
• Debt/equity analysis of financial instruments
• Pillar II assessment
• Substance health-check, review and guidelines
• CFC analysis
• Analysis of the potential tax impact of the upcoming legislations on the existing structure (e.g., EU Directives – DAC 7, ATAD 3; OECD actions)
• ATAD 2 analysis and restructuring options
• Family office & private clients support
• Family business services
• VAT advisory services (VAT team)

With the increase in tax audits or queries from the Luxembourg tax authorities, it has become crucial for Luxembourg companies to prepare adequate documentation in a timely manner to support their positions regarding specific tax or transfer pricing regulations. Our range of services notably includes:

• CFC analysis memorandum
• ATAD 1 and 2 analysis memorandum
• Transfer pricing documentation for intra-group transactions dealt with by our transfer pricing team.

In an ever fast changing tax environment, companies are facing increasingly complex regulatory obligations. Our team will help you navigate through those obligations so that you can spend more time on your core activities. Examples of the support we offer include:

• DAC 6 reporting and health-check, including ad hoc advice
• Preparation of Country-by-Country reports and notifications
• FATCA/CRS classification and reporting assistance
• UBO register declaration

Rigorous management of tax compliance obligations is critical to your business success. Our teams provide a comprehensive range of compliance services, including:

• Implementation of a fully digitalized dashboarding solution customized to your needs to help streamline and efficiently manage your obligations
• Preparation and filing of direct tax returns
• Review or preparation of tax provisions, including review or computation of deferred taxes and reconciliation of effective tax rate
• Net wealth tax assessment and advice
• Pillar II compliance
• Review of the tax assessments and communications from the Luxembourg tax authorities
• Preparation of VAT tax returns (VAT team)

Our teams assist with communication with the Luxembourg tax authorities at various stages of your business life cycle:

• Preparation and submission of tax rulings
• Preparation and submission of advance pricing agreements (lead by our transfer pricing team)
• Functional currency requests
• Fiscal unity requests
• Tax controversy and dispute services: tax audit support, negotiation with tax authorities, administrative appeal, litigation in tax courts, tax mediation, MAP Experience