On 17 June 2022, the Luxembourg Tax Authority published Circular n°164ter/1 (the guidance) on the controlled foreign corporation (CFC) rules. The guidance includes the following topics:
- Foreign controlled companies with regard to corporate income tax;
- The effective tax level of the controlled foreign company;
- Determination of CFC profits;
- Exemption thresholds relating to profit according to the commercial balance sheet;
- Double taxation prevention rules relating to net income included; and
- Controlled foreign companies for business tax.
