Luxembourg Adds Another Hurdle for Tax Authorities Requests for Information

Going forward, tax authorities in Luxembourg will be required to prove that information requested by a foreign government has foreseeable relevance to be included as part of a tax investigation, after the Law on Exchange of Information in Tax Matters (for disclosure requests) was given parliamentary ascent into national legislation in Luxembourg.

The legislation is in line with the European Court of Justice's judgment in the Berlioz case (C-682/15). The new law was passed earlier this month and amends previous regulations, which additionally grants the request's recipient a right of appeal to the administrative court.