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Abstract
Transfers to Luxembourg Articles 35 and 43 of the Income Tax Law (ITL), which already broadly addresses transfers to Luxembourg, will be amended to specifically cover a transfer of tax residence, the activities of a permanent establishment (PE) and assets from another country to Luxembourg. With respect to such transfers, Luxembourg will use the value of the assets as determined by the departure state for tax purposes unless that value is not comparable to the fair market value as defined in the ITL. Transfers out of Luxembourg The scope of Article 38 of the ITL relating to transfers out of Luxembourg has been extended to ensure that, in specific cases, taxpayers in Luxembourg are subject to tax on the transfer of assets (either part of an enterprise, a PE or isolated assets as part of the net invested assets) from Luxembourg to any other jurisdiction in an amount equal to the fair market value of the transferred assets at the date of exit less their tax value.