Luxembourg introduces comprehensive tax reforms for 2025
On 17 July 2024, draft legislation No. 8414 was proposed to the Luxembourg Parliament, introducing new tax measures aimed to improve Luxembourg's competitiveness and appeal to businesses, investors, and foreign talent.
Here’s a concise overview of the key points:
Corporate tax reforms
- Corporate income tax (CIT) reduction: Starting from 2025, the CIT rate will decrease by 1 per cent. Therefore, the companies with taxable profits below €175,000 will see a reduction from 15 per cent to 14 per cent, and those with profits exceeding €200,000 will see a decrease from 17 per cent to 16 per cent. This aligns Luxembourg’s CIT near to the OECD and EU averages.
Exchange-Traded Funds (ETF) and Private Wealth Management Companies (SPF) adjustments
- ETF tax exemption: The Draft Law extends the existing subscription tax exemption for passively managed ETFs to include actively managed ETFs.
- SPF - Several changes include:
- The corporate designation must contain “société de gestion de patrimoine familial” or “SPF”.
- The minimum annual subscription tax increases from €100 to €1,000.
- Compliance certificates must be filed electronically.
Restrictive measures for non-compliance with SPF regulations
New fines and procedural clarifications will be imposed for breaches of SPF regulations, with fines ranging up to €250,000 and additional penalties for continued non-compliance.
Individual tax measures
- Inpatriate regime overhaul: From financial year 2025, the current exemptions will be replaced with a 50 per cent exemption on gross annual salaries up to €400,000 for highly skilled foreign workers.
- Youth employment bonus: below certain threshold, a new 75 per cent exemption on bonuses for employees under 30 entering their first permanent job will be introduced, applicable for five years.
- Enhanced profit-sharing bonuses: The participative bonus regime will now allow bonuses to represent up to 30 per cent of an employee’s annual gross salary and 7.5 per cent of the previous year's profit.
- Tax credit for cross-border workers: Up to €700 tax credit will be introduced for overtime remuneration of cross-border workers subject to double taxation.
- Inflation adjustment: The tax scale will be adjusted to inflation.
Support for lower-income taxpayers
Starting in fiscal year 2025, targeted measures to ease the tax burden for lower-income taxpayers include revising the tax scale for Class 1a, which covers single-parent households, widowed persons, and those over 64, increasing the tax-exempt tranche to €26,460. The single-parent tax credit will rise to €3,504 annually, the allowance for children living outside the household will increase to €5,424, and the minimum social wage tax credit will be raised to €81 monthly, ensuring non-qualified minimum wage earners are not taxed regardless of their tax class.
The draft law No. 8414 (in French) can be accessed here.