Alexandre Leger Cattarini

📢 On 12 August 2025, the Luxembourg tax authorities issued an administrative circular (the Circular – Circular L.I.R n°168quater/2) providing some guidance on their interpretation of the Collective Investment Vehicle (CIV) carve-out of the reverse hybrid rules provided for by article 168quater, paragraph 2 of the Luxembourg Income Tax Law (LITL). Read more about it here 👉 https://lnkd.in/da9Nqus5 #PwCFlash #Tax #Luxembourg

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🚨French Digital Services Tax (DST): A Game-Changing Court Decision Inspired by VAT Concepts! On September 23, 2025, the Tax Court of Cergy-Pontoise issued a notable decision in favor of a digital marketplace, granting partial restitution of the French Digital Services Tax (DST). The Court found that certain services provided to users—when considered separable and independent from the main digital intermediation service—should be excluded from the DST taxable base. What’s particularly interesting is the Court’s approach: it applied VAT concepts to determine whether a group of services constitutes a single taxable operation or several distinct, independently taxed services. This interpretation is a bit different from the position taken by the French tax authorities in their official guidelines. For digital platform and marketplace operators, this decision highlights the value of drawing on VAT case law when assessing DST obligations. Each service should be carefully reviewed to determine whether it must be included in the DST base. For more details on how this might affect your business, feel free to contact read the latest insight from our experts, Bertrand Jeannin and Jean-Charles Orsini : [https://deloi.tt/46Ykr82] #DeloitteFrance #DST #VAT

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France is a wonderful place to live. But for Americans, it may not be the best place to die. While the U.S. estate tax system offers each individual a lifetime exemption of over $14 million, France takes a very different approach: → Inheritance tax applies to worldwide assets if you are a French tax resident at the time of death → The exemption in direct line is only €100,000 per child and per parent, renewable every 15 years → No spousal portability, and rates can quickly climb to 45% But this doesn’t mean France should be avoided altogether, far from it. For those who move here for lifestyle, family or long-term plans, anticipating these rules makes all the difference. There are several planning opportunities available to U.S. citizens: ✔︎ Under the U.S.-France estate tax treaty, U.S. real estate remains taxable in the U.S., and France will credit the French tax due on such assets ✔︎ French property can be acquired under a dismembered ownership (usufruct/bare ownership), which may help reduce exposure on both sides ✔︎ Life insurance solutions can be used to cover potential inheritance taxes, but most U.S. products (such as ULIs) must be subscribed before becoming French tax resident For those who consider France as a life project rather than a tax strategy, the key is to plan early, before residency is triggered, and always in coordination with U.S. counsel. France may not match the U.S. when it comes to estate tax efficiency, but with the right structure in place, it doesn’t have to be a liability. Cross-border estate planning doesn’t have to be complex, when it’s done early. I regularly assist U.S. families with pre-immigration planning and French structuring.

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The Luxembourg tax administration has clarified what qualifies as an undertaking for collective investment under article 168 quater of the Income Tax Law.   The circular confirms automatic UCI status for UCITS, Part II UCIs, SIFs and RAIFs, while setting out key conditions for other funds. This guidance provides welcome certainty for the fund industry - but what does it mean for your Luxembourg vehicle?   Read more: https://lnkd.in/e7E_CYVM

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All entities registered with the Luxembourg Trade and Companies Register have until 1 October 2025 to update the Luxembourg national identification numbers of all individuals recorded in their file. This includes shareholders, directors, managers, day-to-day managers and auditors.  To prevent any disruptions in your entity’s administration and operations, it is strongly advised to verify whether all individuals concerned already have a Luxembourg national identity number (LNIN) or need to request one, and to complete all necessary actions ahead of the deadline.  Do you need to take action? Read our briefing to find out more: https://loom.ly/Ew9m9Jg #Luxembourg #LegalServices #Regulatory #LNIN #RCS

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The evolving EU tax agenda: Pillar Two, Unshell and decluttering Sasha Kerins, International Tax Partner at Grant Thornton Ireland, and Monique Pisters, Head of Tax at Grant Thornton Netherlands, discuss the shifting EU tax landscape. They explore the implications of recent G7 and US announcements on Pillar Two, the EU’s decision to pause the Unshell Directive (ATAD 3), and the momentum behind the decluttering agenda.   🎥 Watch the teaser below and catch the full video in the link: 👉https://bit.ly/3JDLqOl #EUTax #DirectTax #EU #G7 #DAC6 #ATAD3

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For decades, Mauritius has said: “keep your intercompany transactions at arm’s length.” But there was no follow-up - no requirement to prove it. The Finance Act 2025 changes that. Documentation is now compulsory. Companies must demonstrate clearly and on record how their pricing meets the arm’s-length test. This isn’t box-ticking - it’s a major shift that could impact how groups structure their operations and defend themselves under scrutiny. Now is the time to move from principle to practice. Read more in the article on Regan van Rooy's website: https://lnkd.in/dDKukb5f #Mauritius #TransferPricing #internationaltax

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