Luxembourg – Clarification of the concept of partial exemption

In decision no. 2024TALCH14/00058 , the 14th Chamber confirmed the position of the 3rd Chamber and the AEDT. A company is automatically classified as a partial taxable person if it carries out both traditional economic activities subject to VAT and holds shares in various subsidiaries without interfering in their management (activities outside the scope of VAT). This status denies partial taxpayers the right to full deduction.