AGEFI Luxembourg14Mars 2019

Economie

By Oliver R. HOOR, ATOZ Tax Advisers *

Over the last decades,Luxembourg has emer-ged to the location of

choice for the structuring ofAlternative Investments (realestate, private equity, etc.) inand through Europe. Theattractiveness of Luxembourgis linked to a host of factors,which have made it an essentialpart of the global financial archi-tecture.

These factors include its flexible anddiverse legal, regulatory and taxframework, investor andlender familiarity with thejurisdiction, the availabili-ty of qualified, multilin-gual workforce, the exis-tence of a deep pool ofexperienced advisers andservice providers, a large taxtreaty network, an investor-friendly business and legal envi-ronment, and political stability, to namea few reasons. Moreover, Luxembourg is afounder member of and sits at the heart of theEuropean Union, one of the largest sources of cap-ital and investment opportunities globally.

The Luxembourg Parliament has now adoptedthe 2019 tax reform implementing the EU Anti-TaxAvoidance Directive (“ATAD”) and other anti-BEPS-related measures into Luxembourg tax law.More precisely, the 2019 tax reform includes taxlaw changes in the following areas:- Interest limitation rules;- General anti-abuse rule (GAAR); - Controlled foreign companies (CFCs); - Hybrid mismatch rules; - Amendment of the exit tax rules;- Amendment of the roll-over relief; and- Amendment of the permanent establishmentdefinition.

This is the second of two articles that provide aclear and concise overview of the different taxmeasures and analyses their impact on typicalAlternative Investments (real estate, private equity,etc.) made via Luxembourg.

Controlled Foreign Company (CFC) Rules

Companies that are part of the same group aregenerally taxed separately as they are separatelegal entities. When a Luxembourg parent compa-ny has a subsidiary, the profits of the subsidiary areonly taxable at the level of the parent companyonce the profits are distributed. Depending on theresidence state and tax treatment of the subsidiary,dividend income may either be tax exempt (in fullor in part) or taxable with a right to credit a poten-tial withholding tax levied at source.(1) Thus, if aforeign subsidiary is located in a low-tax jurisdic-tion, the taxation of the profits of such entity maybe deferred through the timing of the distribution.

In this regard, ATAD requires EU Member Statesto implement CFC rules that re-attribute theincome of a low-taxed controlled company (orpermanent establishment) to its parent companyeven though such income has not been distribut-ed. However, EU Member States have a certainleeway when it comes to the implementation ofthe CFC rules. More precisely, legislators maychoose between two alternatives regarding thefundamental scope of the CFC rules (i.e. the pas-sive income option vs. the non-genuine arrange-ment option) and have the option to exclude cer-tain CFCs.

Definition of CFCs

According to Article 164ter of the LITL, a CFC is anentity or a permanent establishment of which theprofits are either not subject to tax or exempt fromtax in Luxembourg provided that the followingtwo cumulative conditions are met:

(i) In the case of an entity, the Luxembourg corpo-rate taxpayer by itself, or together with its associat-ed enterprises:a) holds a direct or indirect participation of morethan 50% of the voting rights; or b) owns directly or indirectly more than 50% ofcapital; or c) is entitled to receive more than 50% of the prof-its of the entity (the “control criterion”)

and

(ii) the actual corporate tax paid by the entity orpermanent establishment is lower than the differ-ence between (i) the corporate tax that would havebeen charged in Luxembourg and (ii) the actualcorporate tax paid on its profits by the entity orpermanent establishment (the “low tax criterion”).

In other words, the actual tax paid isless than 50% of the tax that

would have been due inLuxembourg. Given the cur-rently applicable corporateincome tax rate of 18% (thisrate should be reduced to 17%as from 2019 based on recentannouncement of theLuxembourg Gover-nment), the CFC rule will

only apply if the taxation ofthe profits at the level of the

entity or permanent establish-ment is lower than 9% (8.5% as

from 2019) on a comparabletaxable basis.(2)

When assessingthe actual taxpaid by the

entity or per-manent estab-lishment onlytaxes that are

comparable to theLuxembourg corporateincome tax are to be con-

sidered.(3)

Exceptions

The Luxembourg legislator adopted the optionsprovided under ATAD according to which thefollowing entities or permanent establishmentsare excluded from the scope of the CFC rules:- An entity or permanent establishment withaccounting profits of no more than EUR 750.000; or - An entity or permanent establishment of whichthe accounting profits amount to no more than10% of its operating costs for the tax period.(4)

Determination and tax treatment of CFC income

CFC income is subject to corporate income tax ata rate of currently 18%.(5) However, a specificdeduction has been included in the municipalbusiness tax law to exclude CFC income fromthe municipal business tax base.(6) With regard tothe fundamental scope of the CFC rules,Luxembourg has opted for the non-genuinearrangement concept. Accordingly, aLuxembourg corporate taxpayer will be taxedon the non-distributed income of an entity orpermanent establishment which qualifies as aCFC provided that the non-distributed incomearises from non-genuine arrangements whichhave been put in place for the essential purposeof obtaining a tax advantage.

In practice, this means that the profits of a CFCwill only need to be included in the tax base of aLuxembourg corporate taxpayer if, and to theextent that, the activities of the CFC that generatethese profits are managed by the Luxembourgtaxpayer (i.e. when the significant people func-tions in relation to the assets owned and the risksassumed by the CFC are performed by theLuxembourg corporate taxpayer). Conversely,when a Luxembourg parent company does notcarry out any significant people functions in rela-tion to the activities of the CFC, no CFC income isto be included in the corporate income tax base ofthe Luxembourg parent company.(7)

When a Luxembourg corporate taxpayer isinvolved in the management of the activities per-formed by the CFC, the CFC income to be includ-ed by the Luxembourg corporate taxpayershould be limited to amounts generated throughassets and risks which are linked to significantpeople functions carried out by the Luxembourgtaxpayer. Here, the attribution of CFC incomeshall be calculated in accordance with the arm’slength principle(8)(9).

The income to be included in the tax base shallfurther be computed in proportion to the taxpay-er’s participation in the CFC and is included in thetax period of the Luxembourg corporate taxpayerin which the tax year of the CFC ends.

Last but not least, Article 164ter of the LITL pro-vides for rules that aim to avoid the double taxationof CFC income (for example, when CFC income isdistributed or a participation in a CFC is sold).

Analysing the Impact onAlternative Investments

Alternative Investments are generally made inhigh-tax jurisdictions. Here, the CFC rules do notapply in the absence of low-taxed subsidiaries.

When investments are made into a group ofcompanies that has a subsidiary in a low-taxjurisdiction, the Luxembourg CFC rules shouldonly apply if and to the extent the Luxembourgcompany performs the significant people func-tions in regard to the activities performed by theCFC. However, this is a scenario that shouldhardly ever occur in practice.

Anti-hybrid Mismatch Rules

The tax reform law further introduced a newarticle 168ter LITL which implements the gener-ic anti-hybrid mismatch provisions included inATAD. The new provision aims to eliminate - inan EU context only - the double non-taxation cre-ated through the use of certain hybrid instru-ments or entities.

The law does not implement though the amend-ments introduced subsequently by ATAD 2 toATAD which have replaced the anti-hybrid mis-match rules provided under ATAD and extendedtheir scope of application to hybrid mismatchesinvolving third countries. ATAD 2 provides forspecific and targeted rules which have to be imple-mented by 1 January 2020. As such, the anti-hybridmismatch rule provided in ATAD did not have tobe implemented in 2019.

The objective of the measures against hybrid mis-matches is to eliminate double non-taxation out-comes created by the use of certain hybrid instru-ments or entities. In general, a hybrid mismatchexists where a financial instrument or an entity istreated differently for tax purposes in two differ-ent jurisdictions. The effect of such mismatchesmay be a double deduction (i.e. a deduction intwo EU Member States) or a deduction of thepayment in one state without the inclusion of thepayment in the other state.

However, in an EU context, hybrid mismatcheshave already been tackled through several mea-sures such as the amendment of theParent/Subsidiary-Directive (i.e. dividendsshould only benefit from the participationexemption regime if the payment is notdeductible at the level of the paying subsidiary).Therefore, the hybrid mismatch rule included inthe new article 168ter LITL should have a limitedscope of application. However, given the genericwording of the anti-hybrid mismatch rule, the lat-ter may create significant legal uncertainty in2019 even if the existence of a hybrid situation isnot at all linked to tax motives.

Rule applicable to double deduction

To the extent that a hybrid mismatch results in adouble deduction, the deduction shall be givenonly in the EU Member States in which the pay-ment has its source. Thus, in case Luxembourg isthe investor state and the payment has beendeducted in the source state, Luxembourg willdeny the deduction. However, this situationshould hardly ever occur in practice.

Rule applicable in case of deduction without inclusion

When a hybrid mismatch results in a deductionwithout inclusion, the deduction shall be denied inthe payer jurisdiction. Therefore, if Luxembourg isthe source state and the income is not taxed in therecipient state, the deduction of the payment willbe denied in Luxembourg. In practice, income thatis treated as dividend income at investor levelshould, in accordance with the current version ofthe EU Parent/Subsidiary Directive, only benefitfrom a tax exemption if the payment was notdeductible at the level of the Luxembourg compa-ny making the payment. Therefore, these situa-tions should generally not occur in an EU context.

How to benefit from a tax deduction in practice

In order to be able to deduct a payment inLuxembourg, the Luxembourg corporate taxpay-er will have to demonstrate that no hybrid mis-match situation exists. Here, the taxpayer will haveto provide evidence to the Luxembourg taxauthorities that either (i) the payment is notdeductible in the other Member State which is thesource state or (ii) the related income is taxable inthe other Member State.

This evidence is primarily provided through thestatements made in the corporate tax returns.Nonetheless, in practice the Luxembourg taxauthorities may ask for further information andproof in this respect.

Analysing the Impact onAlternative Investments

The scope of the new rules is limited to hybrid mis-match situations in an EU context. However, with-in the EU, hybrid mismatches have already beentackled by several initiatives (for example, the anti-hybrid mismatch rule included in theParent/Subsidiary Directive) and double non-tax-ation/deduction outcomes should be fairlyuncommon in practice. Therefore, the 2019 anti-hybrid mismatch rules should have a limitedimpact on investments.

Given their generic nature, however, the anti-hybrid mismatch rules as they stand may still havethe potential to create significant legal uncertainty.For example, in situations when a fund vehicle is

treated as opaque in the EU Member State(s) inwhich the investors are resident, whereas the vehi-cle is treated as fiscally transparent from aLuxembourg tax perspective. In these circum-stances, one may construe that the fund vehicle isa hybrid entity.

Considering the implementation of the compre-hensive anti-hybrid mismatch rules providedunder ATAD 2 in 2020 (applying in an EU contextand in situations involving third states), it wouldbe wise for taxpayers to anticipate the potentialimpact on investments. One particular concern inthis respect relates to Alternative Investments ofUS investors given the particularities of US tax law.

Exit Tax Rules

The tax reform further provides for tax lawchanges in regard to exit taxation that will becomeapplicable as from 1 January 2020. These measuresshould discourage taxpayers from moving theirtax residence and/or assets to low-tax jurisdic-tions. However, to a large extent, Luxembourg taxlaw provided already for exit tax rules.

Rule applicable to transfers to Luxembourg

As far as transfers to Luxembourg are concerned,a new paragraph has been added to article 35 ofthe LITL providing that in case of a transfer ofassets, tax residence or business carried on by apermanent establishment to Luxembourg,Luxembourg will follow the value considered bythe other jurisdiction as the starting value of theassets for tax purposes, unless this does not reflectthe market value. The aim of this linking rule is toachieve coherence between the valuation of assetsin the country of origin and the valuation of assetsin the country of destination. While ATAD limitsthe scope of application of this provision to trans-fers between two EU Member States, the new pro-vision added to article 35 LITL covers transfersfrom any other country to Luxembourg.

Rule applicable to contributions to Luxembourg

The same valuation principles will also apply tocontributions of assets (“supplement d’apport”)within the meaning of article 43 LITL. Thus, whenassets are contributed to a Luxembourg company,the value considered in the jurisdiction of the con-tributing company or permanent establishmentwill be considered as value of the assets for tax pur-poses, unless this does not reflect the market value.

Rule applicable to transfers out of Luxembourg

As far as transfers out of Luxembourg are con-cerned, the tax reform law provides that a taxpay-er shall be subject to tax at an amount equal to themarket value of the transferred assets at the time ofthe exit less their value for tax purposes in case of: - A transfer of assets from the Luxembourg headoffice to a permanent establishment located inanother country, but only to the extent thatLuxembourg loses the right to tax the transferredassets; - A transfer of assets from a Luxembourg perma-nent establishment to the head office or to anotherpermanent establishment located in another coun-try, but only to the extent that Luxembourg losesthe right to tax the transferred assets; - A transfer of tax residence to another countryexcept for those assets which remain connectedwith a Luxembourg permanent establishment; and - A transfer of the business carried on through aLuxembourg permanent establishment to anothercountry but only to the extent that Luxembourgloses the right to tax the transferred assets.

In case of transfers within the European EconomicArea (EEA), the Luxembourg taxpayer mayrequest to defer the payment of exit tax by payingin equal instalments over 5 years. Section 127 of theGeneral Tax law (“Abgabenordnung”) is amendedaccordingly.

Analysing the Impact onAlternative Investments

Investments made via Luxembourg companiesgenerally do not involve transactions that maytrigger exit taxation. Instead, investments aremade and held until the end of the investmentperiod when the investments are sold. It followsthat the amendment of the exit tax rules and theintroduction of linking rules with regard to migra-tions and contributions should have a limitedimpact in this respect.

Amendment of the PermanentEstablishment Definition

As a last measure, the definition of permanentestablishment under Luxembourg tax law(Section 16 of the Tax Adaptation Law) has beenamended.

Continued on next page

The 2019 Luxembourg Tax Reform:

Analysing the Impact on Alternative Investments – Part 2

Mars 201915AGEFI LuxembourgEconomie

Continued page 1

Under the amended permanent establishmentdefinition, the criteria to be considered in order toassess whether a Luxembourg taxpayer has a per-manent establishment in a country with whichLuxembourg has concluded a tax treaty are thecriteria defined in the tax treaty itself. In otherwords, the permanent establishment definitionincluded in the tax treaty will be relevant.

Furthermore, unless there is a clear provision inthe relevant tax treaty which is opposed to thisapproach, a Luxembourg taxpayer will be con-sidered as performing all or part of its activitythrough a permanent establishment in the othercontracting state only if the activity performed,viewed in isolation, is an independent activitywhich represents a participation in the generaleconomic life in that contracting state.

However, tax treaties concluded byLuxembourg generally include the permanentestablishment definition provided in Article 5 ofthe OECD Model Convention that does notentail such requirement. Thus, the amendment

of the Luxembourg PE definition should have nomaterial impact in practice.

Finally, the Luxembourg tax authorities mayrequest from the taxpayer a certificate issued bythe other contracting state according to whichthe foreign authorities recognize the existence ofthe foreign permanent establishment.(10) Suchcertificate is, in particular, to produce whenLuxembourg adopted the exemption method ina tax treaty and the other contracting state inter-prets the rules of the tax treaty in a way thatexcludes or limits its taxing rights. This is toavoid hybrid branch situations that are recog-nized in Luxembourg but disregarded in thehost state of the permanent establishment.

Analysing the Impact onAlternative Investments

Luxembourg companies involved in AlternativeInvestments do generally not operate throughforeign permanent establishments. Therefore,the amendment of the permanent establishmentdefinition should have no impact on alternativeinvestments.

Conclusion

The 2019 tax reform introduces a number of newanti-avoidance rules into Luxembourg tax law.With regard to alternative investments, the inter-est limitation rules (as detailed in the first part ofthis article, included in the February edition ofAGEFI) have to be in the focus of each and everytax analysis, whereas the other tax measuresshould in many cases have a limited effect.Nevertheless, the impact of the tax reform on aparticular investment structure has to be deter-mined on a case-by-case basis.

Anticipating the next tax reform in 2020, taxpay-ers should analyse whether the adoption of thecomprehensive anti-hybrid mismatch rules pro-vided under ATAD 2 may have an impact oninvestments and implement structure align-ments where necessary.

Ultimately, the attractiveness of Luxembourg asa prime location for the structuring of alternativeinvestments should not be undermined by thecurrent tax developments. To the contrary,Luxembourg offers an ideal framework forinvestments in the post-BEPS era.

* Oliver R. Hoor is a Tax Partner (Head of Transfer Pricing and theGerman Desk) with ATOZ Tax Advisers (Taxand Luxembourg).

The author wishes to thank Samantha Schmitz (Chief KnowledgeOfficer) for her assistance.

The author may be contacted at: oliver.hoor@atoz.lu

1) Article 97 (1) No. 1 of the Luxembourg Income Tax Law (“LITL”) inconnection with Article 166 (1) (Luxembourg participation exemptionregime), Article 115 No. 15 (50% tax exemption for dividends receivedfrom certain subsidiaries when the conditions of the participation exemp-tion regime are not med) or Article 134bis (tax credit) of the LITL.2) Article 164ter (1) of the LITL.3) Article 164ter (1) of the LITL.4) Article 164ter (1) of the LITL.5) According to an announcement of the Luxembourg government, thecorporate income tax rate should be decreased to 17% with retroactiveeffect as from 1 January 2019.6) Section 9 (3a) of the Luxembourg municipal business tax law.7) Article 164ter (4) No. 1 of the LITL.8) The arm’s length principle is formally specified in Articles 56 and 56bisof the LITL.9) Article 164ter (4) No. 1 of the LITL.10) This certificate should mainly evidence that the permanent establish-ment is recognized in the other contracting state. As there is generally nosubject to tax requirement in tax treaties concluded by Luxembourg, thetax treatment of the income derived through the permanent establishmentin the host state thereof should be irrelevant for the tax treatment inLuxembourg.

By Gary CYWIE*, Elvinger Hoss Prussen

Digital ledger technolo-gies («DLT») andblockchains in par-

ticular could disintermedi-ate some of the main finan-cial markets post-trade pro-cesses, fund distributionand the asset servicingvalue chain more generally,authors and experts say(1).Certain authors believe thatmarkets would become moreefficient if the holding, clearingand settlement of securities aswell as post-trade reportingwere made throughblockchains(2).

For example, trans-action costs would belower and transac-tions could be settledin close to real-time. These new tech-nologies would also pro-vide greater transparencyfor regulators (including with respect toKYC/AML) and investors. Even more, theywould eliminate a number of risks associatedwith intermediation. In fact, it would putinvestors back in the position in which they werebefore the introduction of information technolo-gy in the financial markets sector: in direct contactwith the issuer(3). Nothing seems to impede suchdevelopments from a purely technical point ofview. Current national and cross-border legal andregulatory regimes may not, however, be fullyready to govern such developments effectively.

As one of the first cornerstones of theLuxembourg legal landscape in relation to DLT’simpact on the financial sector (which local play-ers must learn to domesticate if Luxembourg isto keep its leading position in the global fundand asset servicing industry), the Luxembourggovernment has on 27 September 2018 pub-lished a Bill of Law 7363 (the «Bill of Law»)which has been approved by parliament on 14February 2019 (the «Amendment») inserting anew Article 18bis in the amendedLuxembourg Law of 1st August 2001 concerningthe circulation of securities (the «2001 Law»), asfollows (free translation):

«Art. 18bis. (1) The account keeper may hold securitiesaccounts and register securities in securities accountswithin or through secure electronic registrationdevices, including distributed electronic registers ordatabases. Successive transfers registered in such asecure electronic registration device are consideredtransfers between securities accounts. The holding ofsecurities accounts within, or the registration of secu-rities in securities accounts through, such a secure elec-tronic registration device do not affect the fungibility ofthe securities concerned.

(2) Neither the application of this law, nor the locationof the securities which continue to be held with the rel-evant account keeper, nor the validity or enforceabilityof the security interests or collateral arrangements cre-ated under the amended Law of 5 August 2005 onfinancial collateral arrangements shall be affected bythe holding of securities accounts within, or by the reg-istration of securities in the securities accountsthrough, such a secure electronic registration device.»

Although account keepers could, from a legalstandpoint, and did in practice already use vari-

ous technologies to hold securities insecurities accounts (e.g. through the

major clearing and settlementproviders), the Amendment pro-vides additional legal certainty byexpressly allowing securities to beregistered and held via secure

electronic registration devices,including distributed electronicregisters or databases.

Notwithstanding certain state-ments in the commentary of the

Bill of Law (the «Commentary»), theissuance of securities is not the subjectmatter of the 2001 Law. The 2001 Law

and in turn the subject matter ofthe Amendment solely relate to

the holding and circulation ofsecurities. Therefore, the

Amendment doesnot intend to gov-ern online issuanceof securities orICOs(4) for example.

The Commentarymakes an explicit ref-

erence to blockchain,which is however only

one of the possible technologiesthat could qualify as a distributed

electronic register (i.e. DLT) and therefore evenmore so as an electronic registration device. Inthis respect, it is important to note that the text ofthe Amendment itself remains technologicallyneutral. Although there may be practical discus-sions on whether electronic registration devicesare secure, giving a definition would haveunnecessarily limited the scope of the legal inno-vation. The fact that account keepers have tocomply with all their duties stemming from theirstatus as regulated entities provides in itselfguarantees of security in this respect.

The Commentary further specifies that, in thesecurities accounts world, a «token» stored in ablockchain should be considered as an «electron-ic asset» representing the security, as in the caseof a paper security or a traditional demateri-alised security. Hence, the token would bethe instrumentum representing the security. Theholding of the instrumentum would be, in thesame way as with other forms of representation,a matter of proof of holding the relevant securityand not a matter of validity of the security, i.e. ofthe rights attaching thereto.

Finally, the text of the Amendment specifies thatthe application of the 2001 Law will not other-wise be affected by this form of holding of secu-rities, including with respect to the principle offungibility, the location of the securities con-cerned (implicit reference seems to be made tothe place of the relevant intermediary approach)as well as the validity and enforceability of col-lateral arrangements within the scope of theamended Law of 5 August 2005 on financial col-lateral arrangements.

The Council of State, in its opinion of 14November 2018(5), made no comment other thansaying that the authors of the Bill of Law con-fined themselves to partially adopt a new formof dematerialisation. It would have been possi-ble, they argue, to grant an official ownershipright over the security represented by the token.This would, however, have needed a more glob-al analysis of the applicable law in respect of thesecurity, the methods of enforcement of suchownership rights towards third parties and otherancillary questions such as the possibility topledge the security.

The Chamber of Commerce, in its opinion of 12December 2018(6), insisted on the fact that the word-ing of the Commentary may give the impressionthat only blockchains would be covered by the con-cept of distributed electronic databases (which theChamber of Commerce says is not the case). Also,the Chamber of Commerce points out that tokensare not necessarily fungible in all blockchains. Intheir view, the Bill of Law should have stated that itall depends on the technology used but thatblockchains can introduce fungible tokens.Without entering into any technical debate here, itis important to note in this respect that theAmendment provides for the fungibility of theunderlying securities, not of the tokens themselves.

In other words, the Amendment only says that ifthe relevant underlying securities are fungible inthe first place, such fungible nature is not affectedshould the account keeper hold the underlyingsecurities within, or registers them through, asecure electronic registration device, indepen-dently from whether or not the tokens are them-selves fungible.

The Amendment was taken as part ofLuxembourg’s efforts to promote digitalisation and

the use of new technologies, and remain the go-totechnology hub in Europe in all fields including thecirculation of securities. In our view it is an impor-tant step in building the future of Luxembourg as afund distribution and asset security jurisdiction.

* Gary Cywie, Counsel, Elvinger Hoss Prussen, is involved in various ITand blockchain-related initiatives and regularly speaks about legal mattersinvolved with such technologies.

1) See for example KPMG Luxembourg (2016), Blockchain could replacepost-trade intermediaries (https://home.kpmg.com/lu/en/home/.../blockchain-could-replace-intermediaries.html), Deloitte Luxembourg, Blockchain impact on funddistribution (https://www2.deloitte.com/content/dam/.../lu_impact-blockchain-fund-distribution.pdf) and De Meijer, Carlo R.W. (2018) What future role forCDSs in blockchain post-trade environment?, Finextra(https://www.finextra.com/blogposting/15143/what-future-role-for-cdss-in-blockchain-post-trade-environment).2) Micheler, Eva and von der Heyde, Luke (2016) Holding, clearing and set-tling securities through blockchain/distributed ledger technology: creating anefficient system by empowering investors,Journal of International Banking& Financial Law, 31 , 11.3) See Oliver Wyman and Euroclear (2016), Blockchain in Capital Markets- The Prize and the Journey (https://www.oliverwyman.com/content/dam/oliver-wyman/global/en/2016/feb/BlockChain-In-Capital-Markets.pdf).4) On ICOs, please see Cywie, Gary (2018) ICO – L’économie numisma-tique, Droit du financement de l’économie, 1, 28 (only available throughLegitech subscription, https://www.legitech.lu).5) Doc. Parl. 7363/01.6) Doc. Parl. 7363/02.

Luxembourg’s confirmation that securities can be held through DLT-like technologies, including blockchains!

Luxembourg’s Parliament Passes Bill 7363

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