New case law developments : tax treatment of losses of a foreign permanent establishment

Journal
Winandy, J-P.
Luxembourg
European Taxation 2006 (Volume 46), No. 2
FormatPDF
EUR
40
| USD
45
(VAT excl.)

The author summarizes an important case in which the Luxembourg Administrative Court of First Instance (confirmed by the Administrative Court) overruled a long-standing administrative practice regarding the tax treatment of foreign losses and permanent establishments in Luxembourg. The potential implications of the decisions for both Luxembourg and EC law are then examined.