Luxembourg: New law on payments to EU ‘black-list’ countries

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Luxembourg: New law on payments to EU ‘black-list’ countries

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On 28 January 2021, the Luxembourg parliament approved bill of law N°7547 implementing measures concerning the non-tax-deductibility of interest and royalty payments made to entities located in non-cooperative jurisdictions.

The bill adds a paragraph to Article 168 of the Luxembourg income tax law (the “LITL”) extending non-tax-deductibility to interest and royalties due to a related party established in a country or territory appearing on the EU list of non-cooperative jurisdictions1 (the “EU list”). The new measure will apply to accruals made as of 1 March 2021, based on the version of the EU list published in the Official Journal of the European Union on that date.

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