Capital Markets, Securitization and Debt Investment Fund Platforms: Important Luxembourg Tax Legislation Update

As the end of 2024 draws to a close, Luxembourg aims to introduce an interesting technical update that may globally be of interest for our clients with structures in Luxembourg.

On 11 December 2024, the Luxembourg Parliament approved the introduction of the concept of Single Company Group (Groupe à Entité Unique) within the Luxembourg tax legislation. This introduction should represent a valuable alternative to certain structures adversely impacted by the current interest deduction limitation rules, including securitization vehicles and platforms.

These new rules should apply to financial years starting on or after 1 January 2024. The necessary procedural steps, including publication in the official Luxembourg gazette, are expected to be completed before year end.

This represent a great opportunity for such structures which could benefit from this technical update, and we are available to discuss further the impact of these changes.

Other key tax measures for Luxembourg's financial sector were also approved on the same day and will apply to financial years starting on or after 1 January 2025. Stay tuned for further updates, and feel free to reach out if you would like to discuss how these changes might impact your structures.

Pierrick Romancant (White & Case, Associate, Luxembourg) contributed to the development of this publication.

_{White & Case means the international legal practice comprising White & Case LLP, a New York State registered limited liability partnership, White & Case LLP, a limited liability partnership incorporated under English law and all other affiliated partnerships, companies and entities.}

_{This article is prepared for the general information of interested persons. It is not, and does not attempt to be, comprehensive in nature. Due to the general nature of its content, it should not be regarded as legal advice.}

_{© 2024 White & Case LLP}