The Luxembourg Tax Administration has published the final circular regarding clarification on the tax treatment of limited partnerships. The Tax Administration provides interpretation and clarification regarding both types of limited partnerships, "Société en Commandite Simple“ (SCS) and "Société en Commandite Spéciale“ (SCSp).

The European Court of Justice (ECJ) now has to deal with the question whether Sec. 18 para. 3 of the German Foreign Investment Act (GFIA) infringes the principle of the free movement of capital, ECJ C-560/13 (Wagner-Raith). Sec. 18 para. 3 GFIA, effective until the end of 2003, is the predecessor of Sec. 6 GITA and provides for the application of the German lump-sum taxation to income received from third-country funds. On December 18th, 2014, the Advocate General referred his opinion on the preliminary question of the German Federal Court of Finance (Bundesfinanzhof) in the Wagner-Raith Case to the ECJ.

The countdown for the extension of the automatic exchange of information at EU level, and globally at OECD level, has started. The financial market is envisaging new challenges, both in Europe and globally.