Will the reduction of the Luxembourg corporate income tax rate result in a German controlled foreign company taxation?
On 5 March 2019 the Luxembourg government filed the new finance bill n° 7450 with the Luxembourg parliament. One of the most important corporate tax measures concern the reduction of the maximum corporate income tax rate from the current 26.01 percent to 24.94 percent as of 2019. Thus, Luxembourg corporate holding companies qualify as low-taxed entities within the meaning of the German controlled foreign company rules as of 2019 with a potential filing obligation for German investors.
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