Corporate Tax

Stay focused on your objectives and comply with all requirements

For tax-paying organisations that want to manage their tax obligation efficiently, PwC provides a broad-ranging corporate tax advisory service. Our relationship-based service focuses on delivering tailored solutions to individual business needs, helping to build shareholder value and manage the impact of taxes on your business.

Your challenges

You need to assess risks, seize opportunities and anticipate any threats, based on reliable advice.

  • Mitigation of capital gains tax on the sale of a business asset

  • Establishment of the most beneficial tax model

  • Knowledge of how to extract value out of your organisation

  • Planification to deal with losses in your business

  • Effectiveness of property portfolio

  • Knowledge of what impact tax and regulatory changes will have on your business

How we can help

Our Corporate tax teams can help you to navigate through coming challenges, following notably the OECD Base Erosion Profit Shifting ("BEPS") initiatives that have now for most of them become reality and the up-coming new tax rules under Pillar I and II that will bring an additional layer of complexity in the international tax landscape. 

Our team can help you to set up efficient and practical structures, predict the tax effects of different business models, and avoid tax risks – with recommendations in line with the applicable national and international tax regulations and developments at the supranational and local levels.

We can support you to: 

  • Optimise overall tax take in your business

  • Increase business efficiency

  • Ensure tax compliance

  • Benchmark effective tax rate against competitors

  • Increase profits

Our consultation topics in the area of national and international corporate taxes

Anti Tax Avoidance Directive (ATAD 1) mostly enhance Luxembourg’s main corporate income tax legislation.

ATAD II covers hybrid mismatches with third countries and more categories of mismatches.

Draft minimum substance standard and new reporting obligations upcoming.

The OECD is working full steam on the two-pillar solution of the BEPS 2.0 project.

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OECD BEPS Action Plan

It has now been four years since the Organisation for Economic Cooperation and Development (OECD) published its project recommendations on Base Erosion and Profit Shifting (BEPS). The EU has taken a clear lead, with strong political momentum not only pushing progress, but pressing Member States to police existing measures much more forcefully.

For businesses, the most important consequence of the BEPS measures is the need for behavioural change, at all levels. Building on media pressure, many tax administrations not only introduce tougher measures and seek to restrict tax treaty benefits, but also challenge more and more often any arrangements that, in their view, lack real substance or a truly commercial principal purpose. Greater transparency is the other main theme of the BEPS Project. This of course brings with it new reporting obligations - for example with country-by-country reporting (CbCR) - and organisations must be comfortable that they have systems in place to comply.

The matrix below can help you navigate through the different BEPS action plans as well as the state of play of the measures resulting from each plan.

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Action Measures  
1 Programme of Work on the Tax Challenges arising from the Digitalisation of the Economy (BEPS 2.0)
  • Pillar 1: Unified Approach
  • Pillar 2: Global Anti-Base Erosion Approach

Read more

2, 3, 4, 6, 7 & 15 International Anti-Avoidance Rules
  • EU Anti Tax Avoidance Directive I (ATAD I): Interest expense limitation rules, Controlled Foreign Company Rules, General Anti-Abuse Rules
  • EU Anti Tax Avoidance Directive II (ATAD II): Anti-Hybrid Mismatch Rules
  • Beneficial Ownership
  • Principle Purpose Test
  • Multilateral Instrument

Read more on ATAD I and ATAD II

5 & 12 Abolition of Harmful Tax Regimes, Tax Transparency and Disclosure
  • OECD List of Harmful tax Practices / Preferential tax regimes
  • OECD List of Uncooperative Tax Havens
  • EU DAC 6 Directive: Mandatory Disclosure of cross-border tax arrangements
  • EU Blacklist for tax purposes
  • Economic Substance

Read more on DAC 6

More details in our PwC Flash

8, 9, 10, 13 & 14 Transfer Pricing Alignment, Re-examine Transfer Pricing Documentation and Making Dispute Resolution Mechanisms More Effective
  • Country by Country reporting
  • Dispute Resolution
Read more on CbCR and Dispute Resolution

Measuring and Monitoring BEPS

  • BEPS Data Analysis
  • Tax Disruption

Contact us

Valery Civilio

Tax Partner, PwC Luxembourg

Tel: +352 49 48 48 3109

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