ATOZ & Legitech briefing - Tax AML in the context of asset management: Are you ready for the CSSF audit?

ATOZ & Legitech briefing

On 9 March 2023, our Tax Partner and Head of Transfer PricingOliver R. Hoor, and Tax Partner, Andreas Medler, in partnership with Legitech, will be hosting a briefing looking at Tax AML in the context of asset management.



With the introduction of Circular 17/650 in 2017, as amended by Circular 20/744 in July 2020, the CSSF significantly extended the AML/CFT compliance obligations of the Luxembourg asset management industry. Circular 17/650 was released by the CSSF following the 2017 Luxembourg tax reform which extended the money laundering offence to aggravated tax fraud and tax evasion.

This initial Circular provided general guidance for all entities falling under the supervision of the CSSF to raise suspicions of tax fraud and evasion through a (non-exhaustive) list of common indicators. Circular 20/744 complements these common indicators by new indicators that are to be taken into account specifically in the context of collective investment activities and professionals providing services in that particular sector.

The intensified audit activity of the CSSF makes clear that the latter expects professionals under its supervision to consider these indicators in their risk assessments. In this respect, the risk mitigation measures need to be proportionate to their risk exposure within the specific context of collective investment activities.

However, who exactly is concerned by the Circular? What triggers potential reporting obligations? Which taxes need to be considered when performing a due diligence? And, how can asset managers ensure compliance with the Circular so as to be prepared for CSSF audits? All these questions will be addressed during this webinar.



  1. Background
  2. Scope and objectives of the Circular
  3. Triggering events of reporting obligations (common and specific indicators) and selected practical issues
  4. Overlap with other reporting obligations (e.g. DAC6, Unshell Directive)
  5. How to manage reporting and compliance obligations in practice
  6. Practical case studies


More information and registration here.