--- oa_review_kit: v1 guide_slug: luxembourg-vat-return guide_version: luxembourg-vat-return@2026-04-13T17:54:35.106Z archetype: vat_gst --- # Review kit: Luxembourg VAT Return Thank you for reviewing this Guide. This kit is one file with three parts: how to use it, an interview prompt for your AI, and the Guide itself. ## How to use this kit (3 steps, about 15 minutes) 1. Open the AI you already use (ChatGPT, Claude, Gemini, anything that reads markdown) and paste in everything from "INTERVIEW PROMPT" below, including the Guide at the end. 2. Your AI interviews you like a colleague, one question at a time. Just talk: war stories, walk-throughs, the mistakes you catch. No writing required. 3. Your AI writes your answers up as a single markdown file. Hand it back at openaccountants.com/skills/luxembourg-vat-return/handback (also linked from the Guide page: "Hand back your file"). What you added is published under your name and credential. If your AI cannot produce the exact output format, hand back whatever you have: a revised Guide file, a worksheet, or plain notes. We take those too, and a person reviews them by hand. The format below is the one we can apply straight away. --- # INTERVIEW PROMPT (paste from here down into your AI) You are interviewing a practising accountant about how they actually do the work covered by the attached Guide ("Luxembourg VAT Return", slug `luxembourg-vat-return`). Interview them like a colleague doing a handover. Do not lecture. Ask ONE question at a time and wait for the answer. Chase war stories and specifics: what kind of client, which portal step, how big the penalty was. The rates, thresholds, and citations are our job; we refresh those from primary sources. Capture ONLY what is NOT derivable from law: - order of operations, and what a wrong order corrupts - what to ask a client before computing anything - what to assume when a fact is unknown, and how it gets flagged - the most-missed traps, with penalty size and who falls in - how the portal or filing channel actually behaves - what has to reconcile before anyone signs - when to refuse the work and hand it to a human specialist If the accountant corrects a rate, threshold, or deadline in the Guide along the way, record it in the FACT CORRECTIONS table, but do not steer the interview toward numbers. ## Questions to work through Ask these in order, one at a time. Skip any the accountant has already covered; follow up where a story has specifics worth pinning down. Each question is tagged with the method slot(s) it feeds. 1. [sequence] Walk me through the last VAT return you prepared, start to finish. What did you open first, and why that order? 2. [intake_questions] [evidence] A new client hands you nothing but a bank statement. What do you do before you'll classify a single line? 3. [pattern_library] Which bank-statement line gets misclassified most often in your experience? What does it look like and where should it actually go? 4. [scope_gate] Tell me about a client you refused or referred out. What about their VAT situation made you stop? 5. [trap] When you review a return someone else drafted, what mistake do you catch most often? 6. [conservative_default] When you can't tell if a sale is domestic or cross-border, what do you assume, and how do you mark it? 7. [cross_check] Before you sign, what has to reconcile with what, and how close is close enough? 8. [filing_mechanics] Walk me through filing on the actual portal. What surprises first-timers: the order of forms, what locks, what you can't undo? 9. [judgment_rule] Ever had a client on a simplified scheme where the "simplification" made things worse? How do you decide who belongs on it? 10. [trap] What's the real penalty story you tell clients, the one that actually happened? 11. [evidence] Which claims will you draft from a bank statement but never file without the underlying paper? 12. [unsettled_law] Anything in VAT right now you deliberately won't finalise because the rules are moving? ## Method slots (for tagging the write-up) - `scope_gate` (Scope gate and refusals): when to stop and send the client to a human - `sequence` (Order of operations): what order to do things in, and what a wrong order corrupts - `intake_questions` (Client intake questions): what to ask a client before computing - `evidence` (Documents and evidence): which documents to insist on, and what is draft-grade vs file-grade - `judgment_rule` (Judgment rules): how a practitioner actually picks when the law allows two routes - `conservative_default` (Conservative defaults): what to assume when a fact is unknowable at draft time - `trap` (Traps and most-missed items): the mistakes everyone makes, what they cost, and who falls in - `filing_mechanics` (Portal and filing mechanics): how submission actually works: channel, order, what locks - `cross_check` (Cross-checks before signing): what has to reconcile with what before delivery, and how close is close enough - `pattern_library` (Pattern library): how messy real-world data (bank lines, payout platforms) maps to tax categories - `edge_case` (Edge-case playbook): the client situations that change the method, not just the numbers - `unsettled_law` (Unsettled-law flags): what not to finalise right now, and why - `handback_protocol` (Hand-back protocol): what the finished working paper contains and who reviews it ## Output format: oa-handback v1 When the interview is done, write the answers up as ONE markdown file in exactly this shape. Fill in the reviewer's real name, credential, and email (ask for them at the end if they have not come up). Every method block gets a `### [method:]` heading where `` is one of the 13 slot ids above. Keep `guide_slug` and `guide_version` exactly as given. Omit any section the interview produced nothing for, but keep the headings that remain exactly as shown. The `fact_key` column may be left blank when unknown. ```markdown --- oa_handback: v1 guide_slug: luxembourg-vat-return guide_version: luxembourg-vat-return@2026-04-13T17:54:35.106Z reviewer_name: reviewer_credential: # free text: CPA, EA, ACCA, Steuerberater... reviewer_email: verdict: --- ## METHOD ### [method:filing_mechanics] ### [method:intake_questions] - - ... ## FACT CORRECTIONS | fact_key | current | correct | source | |---|---|---|---| | | | | | ## FLAGS - [unsettled] - [refer] ## NOTES ``` If for any reason you cannot produce this exact format, output the accountant's corrections and methods as clear plain notes instead. The hand-back page accepts plain notes and revised Guide files too; this format is an optimization, never a gate. --- # THE GUIDE UNDER REVIEW --- name: luxembourg-vat-return description: Use this skill whenever asked to prepare, review, or classify transactions for a Luxembourg VAT return (TVA declaration) for any client. Trigger on phrases like "prepare VAT return", "Luxembourg VAT", "TVA Luxembourg", "AED return", or any request involving Luxembourg VAT filing. MUST be loaded alongside BOTH vat-workflow-base and eu-vat-directive. Holding company structures (SOPARFI/SIF/RAIF/SICAR) are in the refusal catalogue. ALWAYS read this skill before touching any Luxembourg VAT work. jurisdiction: LU domain: vat-gst tax_year: 2025 --- # luxembourg-vat-return ## Section 1 — Quick reference **Quick reference field table** | Field | Value | | --- | --- | | Country | Luxembourg | | Standard rate | 17% (lowest in the EU) | | Reduced rates | 14% (wine, certain fuels, advertising printed matter), 8% (gas, electricity, cut flowers, hairdressing), 3% (food, books, medicines, children's clothing, accommodation, restaurants — from 2024) | | Zero rate | Exports, intra-EU B2B supplies | | Return form | TVA declaration | | Filing portal | https://ecdf.b2g.etat.lu (eCDF) | | Authority | AED (Administration de l'enregistrement, des domaines et de la TVA) | | Currency | EUR | | Filing frequency | Monthly (turnover > EUR 620,000), quarterly (EUR 112,000-620,000), annual (< EUR 112,000) | | Deadline | Monthly/quarterly: 15th of month following; annual: 1 May | | Small business exemption | EUR 50,000 (from 2025) | | Companion skills | vat-workflow-base v0.1+, eu-vat-directive v0.1+ | | Contributor | Open Accountants Skills Registry | | Validated by | Pending | **Conservative defaults** | Ambiguity | Default | | --- | --- | | Unknown rate | 17% | | Unknown purchase status | Not deductible | | Unknown counterparty country | Domestic Luxembourg | | Unknown B2B/B2C for EU | B2C, charge 17% | | Unknown business-use | 0% | **Red flag thresholds** | Threshold | Value | | --- | --- | | HIGH single-transaction | EUR 5,000 | | HIGH tax-delta | EUR 300 | | MEDIUM concentration | >40% | | MEDIUM defaults | >4 | | LOW net position | EUR 10,000 | ## Section 2 — Required inputs and refusal catalogue ### Required inputs - **Minimum viable input** — Bank statement. Banks: BCEE (Spuerkeess), BGL BNP Paribas, ING Luxembourg, Banque de Luxembourg, Raiffeisen. (Minimum viable) - **Recommended input** — Invoices, TVA number (LU + 8 digits). (Recommended) - **Ideal input** — Prior TVA declaration, eCDF submission data. (Ideal) ### Refusal catalogue (supplements eu-vat-directive) - **R-LU-1 — Holding company (SOPARFI/SIF/RAIF/SICAR)** — Trigger: client is a holding or fund structure. Message: "Holding company and fund structures have extremely complex TVA positions (often fully exempt with partial recovery issues). Requires specialist adviser." _(R-LU-1)_ - **R-LU-2 — Fund management** — Trigger: management company for investment funds. Message: "Fund management TVA is highly specialized. Escalate." _(R-LU-2)_ - **R-LU-3 — Partial exemption** — Trigger: mixed supplies (extremely common in Luxembourg financial sector). Message: "Pro-rata required. Given Luxembourg's financial sector dominance, this is the norm rather than exception. Flag for reviewer." _(R-LU-3)_ ## Section 3 — Supplier pattern library ### 3.1 Luxembourg banks **Luxembourg banks pattern table** | Pattern | Treatment | Notes | | --- | --- | --- | | BCEE, SPUERKEESS | EXCLUDE for fees/interest | Financial service exempt | | BGL BNP PARIBAS, ING LUXEMBOURG | EXCLUDE | Same | | BANQUE DE LUXEMBOURG, RAIFFEISEN | EXCLUDE | Same | ### 3.2 Government **Government pattern table** | Pattern | Treatment | Notes | | --- | --- | --- | | AED, ADMINISTRATION ENREGISTREMENT | EXCLUDE | Tax payment | | CCSS (Centre Commun de la Securite Sociale) | EXCLUDE | Social security | | REGISTRE DE COMMERCE | EXCLUDE | Registration | ### 3.3 Utilities **Utilities pattern table** | Pattern | Treatment | Notes | | --- | --- | --- | | CREOS, ENOVOS, SUDSTROUM | Domestic 8% | Gas/electricity (reduced) | | POST LUXEMBOURG | Domestic 17% for non-universal services | Universal postal exempt | | TANGO, POST TELECOM, ORANGE LU | Domestic 17% | Telecoms | ### 3.4 SaaS — EU (reverse charge) **SaaS EU pattern table** | Pattern | Treatment | Notes | | --- | --- | --- | | GOOGLE IRELAND, MICROSOFT IRELAND, ADOBE IRELAND | EU reverse charge | | | Note: many SaaS companies bill FROM Luxembourg (Amazon, PayPal) — these are DOMESTIC | Domestic 17% | Check invoice | ### 3.5 SaaS — non-EU **SaaS non-EU pattern table** | Pattern | Treatment | Notes | | --- | --- | --- | | NOTION, ANTHROPIC, OPENAI, FIGMA | Non-EU reverse charge | | ### 3.6 Food and entertainment **Food and entertainment pattern table** | Pattern | Treatment | Notes | | --- | --- | --- | | CACTUS, DELHAIZE, MATCH, AUCHAN | Default BLOCK | Personal provisioning | | RESTAURANT | Domestic 3% (restaurant/catering) | If business entertainment, limited deductibility | ### 3.7 Insurance **Insurance pattern table** | Pattern | Treatment | Notes | | --- | --- | --- | | LA LUXEMBOURGEOISE, FOYER, LALUX | EXCLUDE | Insurance exempt | ### 3.8 Professional services **Professional services pattern table** | Pattern | Treatment | Notes | | --- | --- | --- | | EXPERT-COMPTABLE, REVISEUR | Domestic 17% | | | AVOCAT, NOTAIRE | Domestic 17% | | ### 3.9 Internal transfers **Internal transfers pattern table** | Pattern | Treatment | Notes | | --- | --- | --- | | VIREMENT INTERNE | EXCLUDE | | | SALAIRE | EXCLUDE | | ## Section 4 — Worked examples ### Example 1 — Non-EU SaaS reverse charge **Input:** `NOTION LABS INC ; DEBIT ; EUR 14.68` **Treatment:** Non-EU reverse charge at 17%. Net zero. ### Example 2 — EU service reverse charge **Input:** `GOOGLE IRELAND ; DEBIT ; EUR 850` **Treatment:** EU reverse charge at 17%. ### Example 3 — Restaurant at super-reduced 3% **Input:** `RESTAURANT CLAIREFONTAINE ; DEBIT ; EUR 206` **Treatment:** Restaurant services at 3%. Net = 200. TVA = 6. If entertainment: limited deductibility. Flag. ### Example 4 — Electricity at 8% **Input:** `ENOVOS ; DEBIT ; EUR 216` **Treatment:** Domestic 8%. Net = 200. TVA = 16. ### Example 5 — EU B2B service sale **Input:** `STUDIO KREBS GMBH (DE) ; CREDIT ; EUR 3,500` **Treatment:** Zero-rated. Verify DE USt-IdNr. ### Example 6 — Amazon (billed from LU) **Input:** `AMAZON EU SARL ; DEBIT ; EUR 50` **Treatment:** Amazon EU SARL is a Luxembourg entity — DOMESTIC 17%, not reverse charge. ## Section 5 — Tier 1 classification rules (compressed) ### 5.1 Standard rate 17% - **Standard rate** — 17% percent ### 5.2 Intermediate rate 14% — wine, certain fuels, advertising print - **Intermediate rate** — 14% percent (wine, certain fuels, advertising print) ### 5.3 Reduced rate 8% — gas, electricity, cut flowers, hairdressing - **Reduced rate** — 8% percent (gas, electricity, cut flowers, hairdressing) ### 5.4 Super-reduced rate 3% — food, books, medicines, children's clothing, accommodation, restaurants - **Super-reduced rate** — 3% percent (food, books, medicines, children's clothing, accommodation, restaurants) ### 5.5 Zero rate — exports, intra-EU B2B - **Zero rate** — 0% percent (exports, intra-EU B2B) ### 5.6 Exempt — financial services, insurance, medical, education, residential rental - **Exempt categories** — Financial services, insurance, medical, education, residential rental ### 5.7 EU/non-EU reverse charge — per companion skills - **EU/non-EU reverse charge** — Per companion skills ### 5.8 Blocked input — entertainment (limited), personal use - **Blocked input** — Entertainment (limited), personal use ## Section 6 — Tier 2 catalogue (compressed) ### 6.1 Financial sector TVA — nearly always partial exemption - **Financial sector TVA** — Nearly always partial exemption ### 6.2 Holding company input recovery — flag - **Holding company input recovery** — Flag ### 6.3 Amazon/PayPal LU entities — domestic, not reverse charge - **Amazon/PayPal LU entities** — Domestic, not reverse charge ### 6.4 Restaurant entertainment — 3% but deductibility limited - **Restaurant entertainment** — 3% but deductibility limited ## Section 7 — Excel working paper template Standard layout. Column H accepts Luxembourg TVA box codes. ## Section 8 — Bank statement reading guide **Format:** BCEE/BGL CSV, DD/MM/YYYY, EUR. **Language:** French, German, or Luxembourgish. **Internal transfers:** "Virement interne". Exclude. ## Section 9 — Onboarding fallback ### 9.1 TVA number — "LU + 8 digits?" "LU + 8 digits?" ### 9.2 Filing frequency — infer from turnover Infer from turnover ### 9.3 Financial sector — "Are you in financial services?" (triggers partial exemption) "Are you in financial services?" (triggers partial exemption) ### 9.4 Prior credit — always ask Always ask ## Section 10 — Reference material ### Sources - **Reference sources list** — 1. Loi du 12 fevrier 1979 (TVA Law, as amended) 2. EU VAT Directive 2006/112/EC 3. AED/eCDF — https://ecdf.b2g.etat.lu _(Loi du 12 fevrier 1979 (TVA Law, as amended); EU VAT Directive 2006/112/EC; AED/eCDF — https://ecdf.b2g.etat.lu)_ ### Change log - **v2.0 (April 2026):** Full rewrite to 10-section architecture. - **v1.0:** Initial skill. ## Disclaimer This skill and its outputs are provided for informational and computational purposes only and do not constitute tax, legal, or financial advice. Open Accountants and its contributors accept no liability for any errors, omissions, or outcomes arising from the use of this skill. All outputs must be reviewed and signed off by a qualified professional (such as a CPA, EA, tax attorney, or equivalent licensed practitioner in your jurisdiction) before filing or acting upon. The most up-to-date, verified version of this skill is maintained at [openaccountants.com](https://openaccountants.com). Log in to access the latest version, request a professional review from a licensed accountant, and track updates as tax law changes.