The new IP regime of article 50ter, fully compliant with the OECD’s “nexus approach”, took effect from the 2018 tax year. As a reminder, the previous article 50bis LITL IP regime was closed to new entrant IP with effect from 30 June 2016, although previously qualifying IP can continue to benefit from the old regime during its “sunset” period, running until 30 June 2021.
For further details, please see https://www.pwc.lu/en/tax-consulting/docs/pwc-tax-230318.pdf
The Circular neither amends nor supplements the text of article 50ter. It does however provide explanations and clarifications on a number of items, including the following topics:
The Circular also reconfirms the net wealth tax rules applicable to eligible assets.
The Circular provides helpful and welcome guidance on a number of aspects of the application of Luxembourg’s post 2017 tax regime for intellectual property.
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