The Luxembourg indirect tax authorities or, l’Administration de l’enregistrement, des domaines et de la TVA (AED) recently published new updates concerning the Luxembourg subscription tax.
In summary, the AED remind taxpayers that the transition period for subscription tax filings is coming to an end, announced that CSSF and ISIN codes may now be obtained for RAIF compartments, and introduced the systematic issuance of subscription tax account statements.
In July 2024, the AED issued Circular N°821 announcing new online procedures for filing subscription tax returns for Undertakings for Collective Investment (UCI), Specialized Investment Funds (SIF), and Reserved Alternative Investment Funds (RAIF).
This circular provided for a two-year transition period, where both the old and the new filing procedures operate in parallel. This transition period will now end on 31 August 2026. From this date onward, use of the new filing forms available on MyGuichet will become mandatory and taxpayers will be required to provide additional information as part of their subscription tax returns.
Please refer to our Fund Taxation Alert 2024-09 for an overview of the circular and the new online procedures.
As part of the ongoing transition towards enhanced subscription tax reporting, the AED also recently announced on their website that identifiers (CSSF/ISIN codes) relating to RAIF compartments are now available (the CSSF identification codes assigned to RAIFs).
The publication is intended to assist taxpayers in preparing for the new subscription tax procedures that will become mandatory from August 2026. Under the revised filing framework, additional information will need to be reported, including compartment-level identifiers.
These identifiers are provided for information purposes only. Any missing ISIN codes or discrepancies identified by taxpayers in the published file may be reported to the AED at: tabo.cf@en.etat.lu
Identification codes for UCIs, SIFs and SICARs remain publicly available on the website of the Commission de Surveillance du Secteur Financier (CSSF).
In a separate development, the AED have also announced that the Subscription Tax Office now systematically issues account statements to taxpayers.
The initiative aims to improve transparency by providing taxpayers with a regular overview of their subscription tax position and facilitating the identification of outstanding balances.
Taxpayers should carefully review the statements upon receipt while keeping in mind the following:
These recent initiatives reflect a continued focus on digitalization and transparency. With the August 2026 filing deadline approaching, investment funds and their service providers should take the opportunity to ensure readiness for the upcoming subscription tax compliance requirements.
The AED have recently intensified their scrutiny of subscription tax compliance for investment funds. Current (non-exhaustive) control areas include the classification and eligibility of institutional share classes, the treatment and exemption requests of fund-of-funds structures, the reporting and documentation of money market funds, and the accuracy and timeliness of subscription tax returns (including amended returns).
Funds and their respective investment fund managers are encouraged to review their current processes and documentation to ensure they remain aligned with the relevant requirements.
