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By Keith O’DONNELL, Gilles STURBOIS and Samantha SCHMITZ*
On 29 November 2017, the Luxembourg tax authorities released the highly anticipated circular on stock option/warrant plans (the “Circular”). The publication of the Circular follows the announcement made by Finance Minister Gramegna during his presentation of the 2018 budget, according to which the regime of stock option/warrant plans would be amended soon. The Circular replaces the former circulars 104/2 (20 December 2012) and 104/2bis (28 December 2015) as well as internal administrative guidelines from the tax authorities.
Far from the announced “aggiornamento” of the taxation regime of stock-options, the new Circular only clarifies some of the rules already applied by practitioners and...
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