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So far Coordinateur has created 37 blog entries.

Comparative table on tax regime holding companies

Law & Numbers presents a comparative study on tax regime holding companies. To see the full study, click on the picture : Contributors : Switzerland : Yves Auberson - Felten Assa & Associés France : Céline Boisselier - TGS Avocats United States (USA) : Gregory M. McKenzie - FischerBroyles LLP Hungary : Pal Jalsovszky - Jalsovszky Law Firm Portugal : Sofia Quental - Valadas Coriel & [...]

By | 2023-11-06T15:17:19+01:00 November 6th, 2023|France, Hungary, Luxembourg, portugal, Switzerland, USA|

Portugal : Prime Minister announces intention to end NHR tax programme (Non-Habitual Resident)

Prime Minister António Costa announced on Monday that the state intends to end the Non-Habitual Residents Programme (NHR) in 2024 and will no longer accept taxpayer registrations from next year. However, the Prime Minister wasn’t clear on whether he intended to put an end to the whole scheme and how the new guidelines would be applied, and he guaranteed that those who already benefit from the [...]

By | 2023-10-09T14:17:28+02:00 October 9th, 2023|portugal, taxation|

Suspension of numerous dispositions of Tax Treaties by Russia

As you may know, on 8/8/2023 the Russian President has issued a decree on 'the suspension by the Russian Federation of specific provisions of the international tax treaties of the Russian Federation'. The decree suspends various provisions of Tax treaties with 38 "unfriendly foreign states". Are suspended art. 5 (definition of PE), art. 6 to 22 (allocation of taxing capacity), art. 24 (non-discrimination) and art. 27 [...]

By | 2023-09-26T12:11:20+02:00 September 26th, 2023|Non classé|

How to compute taxable income of Reverse Hybrid Entities in Luxembourg ?

The Luxembourg Tax Authority (“L.T.A.”) has released on the 9th of June2023  a circular LIR N°168 quarter/1 providing guidance on the computation of taxable income of Reverse Hybrid Entities.  A new form to be filed electronically for transparent entities together with Frequently Asked Questions guidance on how to fill in such form are now also available on the website of the L.T.A.  This is of great help, [...]

By | 2023-06-26T18:13:22+02:00 June 26th, 2023|Bernard Felten, Luxembourg, taxation|

Teleworking and permanent establishment (PE) risk

The question I would like to address is linked to the new work practices after the Corona crisis. I mean the new tendency in many companies of allowing staff or certain staff members to telework. This new tendency does not raise any problem from taxation point of view if the telework takes place within the same jurisdiction. But when some members of the staff telework from [...]

By | 2023-06-08T18:06:15+02:00 June 8th, 2023|Andre Bailleux|

Luxembourg Tax Update – 2023 Budget Law

Technical change Legalization of the current administrative practice in terms of deadline for filing tax returns. The 2023 budget law has extended the filing deadline for corporate income tax, municipal business tax, net wealth tax and personal income tax returns from 31 March to 31 December. VAT rates amendments Effective as from 1 January 2023 VAT Cut by 1% but super-reduced rate remains unchanged. From 1 [...]

By | 2023-02-06T12:30:44+01:00 February 6th, 2023|Bernard Felten, Luxembourg, taxation|

Law & Numbers is welcoming a new member: Portugal (represented by João Valadas Coriel of Valadas Coriel & Associados)

We are pleased to welcome João Valadas Coriel to our international network of tax lawyers as a new Portuguese member of our network. Who is João Valadas Coriel ? João Valadas Coriel is an Attorney at law specialised in tax law, registered with the Lisbon Bar. He works in Portuguese, English, French, Spanish and Italian. His practice areas are: corporate and personal taxation, dispute resolution, digital [...]

By | 2022-04-08T18:22:33+02:00 April 8th, 2022|Non classé|

DAC 6 Directive and local implementation in European Union (EU)

DAC 6 is an EU Directive that introduces Mandatory Disclosure Obligations for a wide range of cross-border tax arrangements. EU Countries have aligned their national laws quite closely to the DAC6 Directive but some countries went beyond the content of such Directive adding extra requirements. Addressing these differences is the purpose of this COUNTRY PER COUNTRY review. Click here to read the full article : LN [...]

By | 2022-05-11T17:29:07+02:00 April 7th, 2022|DAC 6, European Union, Hungary, Italy, Luxembourg, taxation|


In its verdicts in the Di Mauro and the Porr cases, the ECJ has given a green light to the reclaim of VAT on bad debts. Notwithstanding, Hungarian taxpayers still had to launch domestic procedures to enforce their rights to reclaim. The Hungarian Supreme Court has recently announced its first decisions in such cases, for the benefit of the taxpayers. To red the full article, click [...]

By | 2021-07-02T19:05:14+02:00 July 2nd, 2021|Hungary|


Based on a new OECD standard, tax authorities will be better placed to monitor the activities of companies registered in tax havens and to access their key financial data. Although it remains to be seen how the Hungarian tax authority will use this information, several popular tax minimisation strategies may be affected. To read the full article, click here : NAV TO HAVE ACCESS TO DUBAI-BASED [...]

By | 2021-07-02T19:01:20+02:00 July 2nd, 2021|Hungary|

Interview with Mr. Bernard Felten of Felten & Associés (Luxembourg)

  Bernard Felten Luxembourg member of the network Felten & Associés   Network coordinator : Hello Bernard You represent Luxembourg in our Law & Numbers network of tax lawyers. We would like to get to know you a little better. If you agree, we will ask you some questions. Bernard Felten : My pleasure ! Network coordinator : What was your background that led you to [...]

By | 2021-06-21T12:00:42+02:00 June 21st, 2021|Luxembourg|

Interview with Mr. Ambrogio Novelli from «Studio Legale Novelli» (Italy)

  Ambrogio Novelli Italian member of the network Studio Legale Novelli     Network coordinator: Hello Mr. Novelli, You represent Italy in our Law & Numbers network of tax lawyers. We would like to get to know you a little better. If you agree, we will ask you some questions. Ambrogio Novelli : Yes, with great pleasure. Network coordinator: What was your background that led you [...]

By | 2021-06-21T11:36:51+02:00 June 21st, 2021|Non classé|

Interview with Pál Jalsovszky from Jalsovszky Law Firm, Budapest (Hungary)

  Pál Jalsovszky Hungarian Member of the network Jalsovszky Law Firm Network coordinator : Hello Pál, You represent Hungary in our Law & Numbers network of tax lawyers. We would like to get to know you a little better. If you agree, we will ask you some questions. Network coordinator : What was your background that led you to the profession of tax lawyer? Pál Jalsovszky [...]

By | 2021-06-21T11:24:07+02:00 June 21st, 2021|Hungary|

Law & Numbers is welcoming a new member: Germany (represented by Christoph Möslein of BAY GmbH)

We are extremely pleased to welcome Christoph Möslein to our international network of tax lawyers as a new German member of our network. Who is Christoph Möslein? Christoph Möslein is an Attorney at law specialised in tax law, registered with the Munich Bar and a Tax consultant, registered with the Chamber of Tax Consultants in Munich. He works in German, English, French and Italian. His practice [...]

By | 2021-05-04T19:03:42+02:00 May 4th, 2021|BAY GmbH, Christoph Möslein, german member, Germany|

Summary of invoicing rules in BEL / ESP / FR / HUN / IT / LUX / USA

Invoicing rules are an important issue for companies. Mistakes may incur a high tax risk, especially with regards to VAT. Our network's tax specialists have prepared a summary of the invoicing rules applicable in each of their respective countries. For EU countries, common rules have been established, to which each country may add its specificities. The EU countries presented in the summary are: Belgium, France, Hungary, [...]

By | 2020-10-29T17:13:12+01:00 October 28th, 2020|Belgium, France, Hungary, Italy, Luxembourg, USA|

Covid-19: Emergency tax measures in each country of Law & Numbers Network

Law & Numbers is an international network of tax specialists bringing together law firms from several countries. In the context of the current pandemic known as Coronavirus or Covid-19, our lawyers present the general and tax emergency measures taken for the following countries: Country Author Belgium André Bailleux Czech Republic Bohdana Prazska France Marylène Bonny-Grandil Hungary Pal Jalsovsky Italy Ambrogio Novelli Luxembourg Bernard Felten Spain José [...]

France : Transfer Pricing and Covid-19

The economic repercussions of the Covid19 health crisis has been, and continues to be, numerous. While these are often clearly identifiable and of immediate impact, others are more subtle and therefore more difficult to identify and anticipate. This is the case for transfer pricing issues generated by the crisis. ADJUSTED PRICES FOR INTRAGROUP TRANSACTIONS Whether it is a distribution entity or a service provider, companies must [...]

By | 2020-08-07T15:02:38+02:00 July 21st, 2020|Covid-19, France, publication|