LUXEMBOURG Trends and Developments Contributed by: Romain Tiffon and Marie Bentley, ATOZ Tax Advisers
Conclusion In 2025–2026, Luxembourg has consolidated its position as a stable and strategically adaptive private wealth jurisdiction. The preservation of long-standing tax advantages, combined with targeted reforms such as the start-up tax credit, the exemption for certain government bonds and the modernised carried inter - est regime, reflects a deliberate policy to enhance competitiveness while ensuring legal certainty. At the same time, the implementation of DAC8 con - firms Luxembourg’s commitment to transparency and alignment with international standards. This balanced approach, maintaining continuity while embrac - ing measured evolution, ensures that Luxembourg remains a reliable, compliant and attractive centre for private wealth structuring.
products and cross-border tax rulings granted to indi - viduals. Targeted advance cross-border rulings are the ones issued, amended or renewed after 1 January 2026 and where: • the amount of the transaction or series of transac - tions of the advance cross-border ruling exceeds EUR1.5 million (or the equivalent amount in any other currency), if such amount is referred to in the advance cross-border ruling; or • the advance cross-border ruling determines wheth - er a person is or is not resident for tax purposes in the member state issuing the ruling. From a private wealth perspective, DAC8 represents a further step toward comprehensive tax transparen - cy, reinforcing Luxembourg’s transition toward a fully compliant financial centre. While it does not introduce new taxes, it significantly enhances the visibility of asset holdings and investment activities, particularly in the digital asset space, thereby increasing compli - ance requirements for both intermediaries and inves - tors.
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