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Incorporating a Luxembourg SARL in cash without a bank account: now possible – Luxembourg introduces deferred payment of minimum share capital.
Thursday, 04 June 2026
With the entry into force on 2 June 2026 of the law of 18 May 2026[1] (“the “Law”), the Luxembourg law of 10 August 1915 on commercial companies (the “Company…
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Luxembourg case law (lower court): share premium reductions may become subject to (up to 15%) Luxembourg dividend withholding tax
Friday, 22 May 2026
In its decision dated 25 March 2026 (Case no. 45846a), the Luxembourg Administrative Tribunal ruled that a repayment of share premium to shareholders, in the absence of a corresponding formal…
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Tiberghien Tax Law Manual 2026 (Dutch edition) available now
Wednesday, 27 May 2026
The Tiberghien Manual of Tax Law 2026 is the latest edition of the leading reference work in Belgian taxation. Since 1955, this manual has provided a comprehensive and reliable overview…
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EU customs reform package: from fragmentation to integration
Tuesday, 07 April 2026
In recent years, the EU Customs Union has faced mounting pressure from several developments. These include the exponential growth of e-commerce—particularly low-value goods largely originating from China—alongside increasing geopolitical tensions…
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Circular letter letter confirms retroactive application of expanded expat regime
Friday, 03 April 2026
At the end of last year, legislative changes were introduced to make the special tax regimes for inbound taxpayers and researchers (the expat regime) more attractive (as explained in our previous newsletter). …
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Antwerp Court of Appeal confirms limits of tax abuse provisions in share deals
Monday, 30 March 2026
In its judgment of 3 February 2026, the Antwerp Court of Appeal provided important guidance on the application of Belgian anti-abuse rules to share deals carried out in the context…
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(Almost) ready to go? Updates on the Belgian Pillar 2 Implementation
Thursday, 26 March 2026
Belgium has taken further steps in the implementation of the OECD/G20 Pillar 2 rules with the publication of (i) the draft Income Inclusion Rule (IIR) return and accompanying draft instructions,…
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Legal 500 ranking 2026 edition
Wednesday, 25 March 2026
Tiberghien receives a Tier 1 ranking for Tax in the 2026 edition of The Legal 500 EMEA. This continues our recognition as a Top Tier Firm in Belgium. We thank all our clients…
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Tax surcharge for non-residents is contrary to the principle of free movement
Wednesday, 18 March 2026
In its decision issued on 12 March 2026, the Court of Justice of the European Union ruled that the tax surcharge applied for non-residents violated European Union law. This tax…
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Changes to the Belgian expat regime: opportunities and key considerations
Monday, 16 March 2026
To make Belgium more attractive for foreign talent, the special tax regime for inbound taxpayers and researchers (“expat status”) was relaxed at the end of 2025.
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Vietnam added to the EU black list of non-cooperative jurisdictions for tax purposes
Monday, 23 February 2026
Last week, the European Union approved an update to the EU list of non-cooperative jurisdictions for tax purposes (the so-called “black list”), officially adding Vietnam alongside the Turks and Caicos…
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Tiberghien announces renewed Board of Directors
Thursday, 05 February 2026
Tiberghien is pleased to present the new composition of its Board of Directors.
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Luxembourg's new Carried Interest Tax Regime formally adopted
Wednesday, 28 January 2026
On 22 January 2026, the Luxembourg parliament approved Bill 8590, confirming the new carried interest regime with effect from 1 January 2026. Luxembourg now offers one of the most attractive…
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CSSF Circular 25/901: Modernisation and clarification of Luxembourg funds framework
Monday, 26 January 2026
On 19 December 2025, the Luxembourg’s financial sector supervisory authority (Commission de Surveillance du Secteur Financier – “CSSF”) published CSSF Circular 25/901 (the “Circular”) relating to specialized investment funds (“SIFs”),…
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Social security without borders: the 25% rule clarified
Thursday, 22 January 2026
Cross-border employment requires a well-considered, multidimensional approach, in which the determination of the applicable social security regime constitutes a crucial element. The European Court of Justice recently ruled that, for…
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Partner and Counsel Promotions at Tiberghien
Friday, 02 January 2026
We are proud to announce that Romina Abiuso has been appointed Partner at Tiberghien as of 1 January 2026. Romina joined our firm in 2008 and has since developed into…
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Introduction of deferred cash payment of minimum share capital for Luxembourg private limited liability companies
Wednesday, 24 December 2025
Opening bank accounts for newly formed entities has become an increasingly common challenge, both in Luxembourg and internationally. In Luxembourg, the incorporation of a private limited liability company (société à…
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Filing deadline extension until 30 June 2026 – QDMTT-returns 2024
Monday, 17 November 2025
Today, the Belgian tax authorities announced a general extension for filing the Qualified Domestic Minimum Top-up Tax (QDMTT) return, introduced by the Law of 19 December 2023 on the minimum…
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ITR World Tax 2026 Guide
Wednesday, 15 October 2025
We’re proud to share that Tiberghien has been recognised in the ITR World Tax 2026 Guide! Tier 1: Tax controversy; Tier 2: General Corporate Tax, Indirect tax, Transfer pricing In…
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Luxembourg on the path of implementation of AIFMD 2
Monday, 13 October 2025
Luxembourg has initiated the process of implementing Directive (EU) 2024/927 as regards delegation arrangements, liquidity risk management, supervisory reporting, the provision of depositary and custody services and loan origination by…



