In 2024, there was a noticeable decline in the number of judgements issues by both the administrative tribunal (the first-instance court for direct tax litigation) and the administrative court (the appeal court), marking a reversal of the upward trend observed in previous years. In 2023, more than 160 judgments were issued in direct tax litigation, while the total number of judgments in 2024 slightly exceeded 100. This is a significant decrease compared to 2022, when the number surpassed 200.

This publication analyses the latest statistics on Luxembourg’s tax litigation landscape, highlights other key developments, and explores changes in litigation strategy and procedures.

The following topics have been at the forefront of Luxembourg tax case law in 2024:

  1. The recognition of foreign permanent establishments
  2. The application of the General Anti-Abuse Rule (GAAR)
  3. Transfer pricing and hidden distributions
  4. Valuation for net wealth tax purposes

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Tax Controversy - Chambers and Partners

Luxembourg chapter