Participation exemption regime
Dividends received may be tax exempt in Luxembourg, according to the so-called
‘participation exemption’ regime, if the conditions described below are satisfied:
• The distributing company is:
• a collective entity falling within the scope of the EU Council ‘Parent Subsidiary
Directive’
• a Luxembourg resident joint-stock company, which is fully taxable and does not
take one of the forms listed the LITL, or
• a non-resident joint-stock company that is fully liable (in its state of residence) to a
tax corresponding to the Luxembourg CIT (i.e. as a general rule, it is required that
the foreign tax is compulsorily levied at an effective rate of at least 10.5%, on a
basis similar to the Luxembourg one).