Avocat a la Cour – International Tax

Avocat a la Cour – International Tax

Linklaters' Luxembourg office in Kirchberg is seeking an Avocat a la Cour for its Tax practice. Luxembourg's extensive double tax treaty network (over 80 treaties), the participation exemption regime, and the IP box regime make it one of the world's most important international tax structuring jurisdictions.

You will advise multinational corporations, PE sponsors, and asset managers on Luxembourg tax aspects of cross-border investment structures, fund formations, and corporate reorganisations.

What You Will Do

• Advise on Luxembourg tax structuring for SOPARFI holding vehicles, fund structures, and securitisation vehicles
• Draft and review advance tax ruling requests to the Administration des Contributions Directes (ACD)
• Advise on the Luxembourg participation exemption, IP box regime, and interest deduction rules
• Advise on transfer pricing compliance and documentation under Luxembourg TP rules
• Support M&A and PE transactions with Luxembourg tax structuring advice

• Advise on Luxembourg tax aspects of cross-border transactions and structures
• Draft tax opinions and advance ruling requests
• Coordinate with international tax teams on multi-jurisdictional planning
• Monitor Luxembourg tax law developments and OECD/BEPS implementation
• Support business development and client relationship management

• Admission to the Barreau de Luxembourg as Avocat a la Cour
• Master in Law and/or Master in Tax; LL.M. in International Tax Law preferred
• 3-6 years of experience in Luxembourg or international tax law
• Knowledge of the Luxembourg Income Tax Law (Loi de l'impot sur le revenu) and double tax treaties
• Fluent in English and French; German is an advantage
• Experience with Luxembourg advance tax rulings is desirable