Proposal for a COUNCIL IMPLEMENTING DECISION amending Implementing Decision 2013/677/EU authorising Luxembourg to introduce a special measure derogating from Article 285 of Directive 2006/112/EC on the common system of value added tax
Date: 2022-07-26
Institutions: Directorate-General for Taxation and Customs Union, European Commission
Subjects: Luxembourg, VAT, derogation from EU law, small business, tax exemption

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   EUROPEAN COMMISSION  Brussels, 26.7.2022  COM(2022) 352 final 2022/0220 (NLE)  Proposal for a COUNCIL IMPLEMENTING DECISION amending Implementing Decision 2013/677/EU authorising Luxembourg to introduce a special measure derogating from Article 285 of Directive 2006/112/EC on the common system of value added tax  
 
EXPLANATORY MEMORANDUM 

Pursuant to Article 395(1) of Council Directive 2006/112/EC of 28 November 2006 on the 
common  system  of  valued  added  tax1  (‘the  VAT  Directive’),  the  Council,  acting 
unanimously on a proposal from the Commission, may authorise any Member State to apply 
special measures for derogation from the provisions of that Directive in order to simplify the 
procedure for collecting VAT or to prevent certain forms of tax evasion or avoidance. 

By  letter  registered  with  the  Commission  on  11  March  2022,  Luxembourg  requested  an 
authorisation  to  continue  to  apply,  until  31  December  2024,  a  measure  derogating  from 
Article  285  of  the  VAT  Directive,  allowing  Luxembourg  to  exempt  from  VAT  taxable 
persons whose annual turnover is no higher than EUR 35 000. 

In  accordance  with  Article  395(2),  second  subparagraph,  of  the  VAT  Directive,  the 
Commission informed the other Member States by  letter dated  7 April 2022 of the request 
made by  Luxembourg. The Commission notified Luxembourg by letter dated  8 April 2022 
that it had all the information necessary to consider the request. 

1. 

• 

CONTEXT OF THE PROPOSAL 

Reasons for and objectives of the proposal 

Chapter 1 of Title XII of the VAT Directive allows for the possibility for Member States to 
apply  special  schemes  for  small  enterprises,  including  the  possibility  of  exempting  taxable 
persons below a certain annual turnover. This exemption implies that taxable persons do not 
have to charge VAT on their supplies and, consequently, they cannot deduct the VAT on their 
inputs. 

The possibility of applying special VAT rules including exemptions or graduated tax relief to 
small  undertakings  was  first  introduced  by  Article  14  of  Council  Directive  67/228/EEC2. 
Member States which did not make use of the option provided for under that provision were 
allowed subsequently, according to Article 24(2)(b) of Directive 77/388/EEC3 now recast as 
the  first  paragraph  of  Article  285  of  the  VAT  Directive,  to  only  exempt  from  VAT  taxable 
persons  whose  annual  turnover  is  no  higher  than  EUR  5 000  or  the  equivalent  in  national 
currency.  Pursuant  to  the  second  paragraph  of  Article  285  of  the  VAT  Directive,  those 
Member States may also grant graduated tax relief to taxable persons whose annual turnover 
exceeds the ceiling fixed by them for its application. 

Until  the  end  of  2012,  Luxembourg  exempted  from  VAT  taxable  persons  whose  annual 
turnover  was  no  higher  than  EUR  10 000.  In  parallel,  Luxembourg  made  use  of  the  option 
pursuant to the second paragraph of Article 285 of the VAT Directive by granting graduated 
tax  relief  to  taxable  persons  whose  annual  turnover  was  between  EUR  10 000  and  EUR 
25 000. 

Subsequently,  Luxembourg  requested  and  obtained  a  derogation  pursuant  to  the  first 
paragraph  of  Article  285  to  apply  a  turnover  threshold  of  EUR  25 000  as  regards  the 

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OJ L 347, 11.12.2006, p.1. 
Second Council Directive 67/228/EEC of 11 April 1967 on the harmonisation of legislation of Member 
States concerning turnover taxes  – Structure and procedures for application of the common system of 
value added tax (OJ 71, 14.4.1967, p. 1303/67). 
Sixth Council Directive 77/388/EEC of 17 May 1977 on the harmonization of the laws of the Member 
States relating to turnover taxes – Common system of value added tax: uniform basis of assessment (OJ 
L 145, 13.6.1977, p.1). 

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exemption scheme for small businesses whilst at the same time abolishing the application of 
tax  relief.  Council  Implementing  Decision  2013/677/EU4  authorised 
the  graduated 
Luxembourg to apply the special measure mentioned above until 31 December 2016.  

By  Council  Implementing  Decision  (EU)  2017/3195  Luxembourg  was  authorised  to  extend 
the expiry date of the special measure to 31 December 2019 and, at the same time, increase 
the  threshold  from  EUR  25 000  to  EUR  30 000.  Then,  by  Council  Implementing  Decision 
(EU)  2019/22106,  the  expiry  date  was  further  extended  to  31  December  2022  and  the 
threshold increased from EUR 30 000 to EUR 35 000. 

Luxembourg requested another extension of that  measure for a limited period.  Luxembourg 
indicated that the special measure reduces administrative burden for both taxable persons and 
the tax authority. It therefore contributes to  the simplification of tax collection, as set out in 
Article  395(1)  of  the  VAT  Directive.  The  measure  is  and  will  remain  fully  optional  for 
taxable persons. 

According to Luxembourg, the special measure pursued would only have a negligible effect 
on the overall amount of VAT revenue collected at the stage of final consumption (not more 
than 0,05%), as required by the second subparagraph of Article 395(1) of the VAT Directive. 
More  specifically,  Luxembourg  reported  that,  in  2020,  633  taxable  persons  with  a  turnover 
between EUR 10 000 and EUR 35 000 made use of the exemption, representing 0,78% of all 
taxable persons. 

The  special  measure,  simplifying  the  obligations  of  small  operators,  is  in  line  with  the 
objectives set out by the European Union for small businesses. 

Given the positive impact on the reduction of administrative burden for businesses and the tax 
administration without a major impact on the total VAT revenue, it is appropriate to authorise 
Luxembourg to extend the special measure until 31 December 2024. 

• 

Consistency with existing policy provisions in the policy area 

The derogating measure is in line with the objectives of Directive (EU) 2020/285 amending 
Articles 281 to 294 of the VAT Directive on a special scheme for small enterprises7, which 
resulted from the VAT action plan8, and aims to create a modern, simplified scheme for those 
businesses.  In  particular,  it  seeks  to  reduce  VAT  compliance  costs  and  distortions  of 

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Council  Implementing  Decision  2013/677/EU  of  15  November  2013  authorising  Luxembourg  to 
introduce  a  special  measure  derogating  from  Article  285  of  Directive  2006/112/EC  on  the  common 
system of value added tax, OJ L 316, 27.11.2013, p. 33). 
Council Implementing Decision (EU) 2017/319 of 21 February 2017 amending Implementing Decision 
2013/677/EU  authorising  Luxembourg  to  introduce  a  special  measure  derogating  from  Article  285  of 
Directive 2006/112/EC on the common system of value added tax (OJ L 47, 24.2.2017, p. 7). 
Council  Implementing  Decision  (EU)  2019/2210  of  19  December  2019  amending  Implementing 
Decision 2013/677/EU authorising Luxembourg to introduce a special measure derogating from Article 
285  of  Directive  2006/112/EC  on  the  common  system  of  value  added  tax  (OJ  L  332,  23.12.2019,  p. 
155). 
Council  Directive  (EU)  2020/285  of  18  February  2020  amending  Directive  2006/112/EC  on  the 
common system of value added tax as regards the special scheme for small enterprises and Regulation 
(EU)  No  904/2010  as  regards  the  administrative  cooperation  and  exchange  of  information  for  the 
purpose  of  monitoring  the  correct  application  of  the  special  scheme  for  small  enterprises  (OJ  L  62, 
2.3.2020, p. 13). 
Communication  from  the  Commission  to  the  European  Parliament,  the  Council  and  the  European 
Economic and Social Committee on an action plan on VAT – Towards a single EU VAT area – Time to 
decide COM(2016)148 final. 

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competition  both  domestically  and  at  EU  level,  reduce  the  negative  impact  of  the  threshold 
effect, and facilitate business compliance as well as monitoring by tax administrations. 

Moreover, the threshold of EUR 35 000 is consistent with Directive (EU) 2020/285, insofar as 
it allows Member States to set the annual turnover threshold required for an exemption from 
VAT at a level no higher than EUR 85 000 (or the equivalent in national currency). 

Similar derogations, exempting from VAT taxable persons whose annual turnover is below a 
certain  threshold,  as  provided for in  Articles 285 and 287 of the VAT  Directive, have been 
granted  to  other  Member  States.  The  Netherlands9  and  Belgium10  have  been  granted  a 
threshold of EUR 25 000; Italy11 a threshold of EUR 30 000; Poland12, Latvia13 and Estonia14 
have  been  granted  a  threshold  of  EUR  40  000;  Hungary15  a  threshold  of  EUR  48  000; 
Lithuania16  a  threshold  of  EUR  55  000;  Croatia17  a  threshold  of  EUR  45  000;  Malta18  a 
threshold  of  EUR  30  000;  Slovenia19  a  threshold  of  EUR  50  000;  Czechia20  a  threshold  of 
EUR 85 000; and Romania21 a threshold of EUR 88 500. 

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Council  Implementing  Decision  (EU)  2018/1904  of  4  December  2018  authorising  the  Netherlands  to 
introduce  a  special  measure  derogating  from  Article  285  of  Directive  2006/112/EC  on  the  common 
system of value added tax (OJ L 310, 6.12.2018, p. 25). 
Council  Implementing  Decision  (EU)  2022/88  of  18  January  2022  amending  Implementing  Decision 
2013/53/EU  as  regards  authorisation  to  the  Kingdom  of  Belgium  to  apply  for  a  further  period  the 
special measure derogating from Article 285 of Directive 2006/112/EC on the common system of value 
added tax (OJ L 14, 21.1.2022, p. 23)  
Council  Implementing  Decision  (EU)  2020/647  of  11  May  2020  authorising  the  Italian  Republic  to 
apply a special measure derogating from Article 285 of Directive 2006/112/EC on the common system 
of value added tax (OJ L 151, 14.5.2020, p. 7). 
Council Implementing Decision (EU) 2021/1780 of  5 October 2021 amending Decision 2009/790/EC 
authorising  the  Republic  of  Poland  to  apply  a  measure  derogating  from  Article  287  of  Directive 
2006/112/EC on the common system of value added tax (OJ L 360, 11.10.2021, p. 122). 
Council  Implementing  Decision  (EU)  2020/1261  of  4  September  2020  amending  Implementing 
Decision  (EU)  2017/2408  authorising  the  Republic  of  Latvia  to  apply  a  special  measure  derogating 
from  Article  287  of  Directive  2006/112/EC  on  the  common  system  of  value  added  tax  (OJ  L  296, 
10.9.2020, p. 4). 
Council Implementing Decision (EU) 2021/358 of 22 February 2021 amending Implementing Decision 
(EU) 2017/563 authorising the Republic of Estonia to apply a special measure derogating from Article 
287 of Directive 2006/112/EC on the  common system of value added tax (OJ L 69, 26.2.2021, p. 4).

Council  Implementing  Decision  (EU)  2022/73  of  18  January  2022  amending  Implementing  Decision 
(EU) 2018/1490 as regards authorisation to Hungary to apply for a further period the special measure 
derogating from Article 287 of Directive 2006/112/EC on the common system of value added tax (OJ L 
12, 19.1.2022, p. 148). 
Council  Implementing  Decision  (EU)  2021/86  of  22  January  2021  authorising  the  Republic  of 
Lithuania  to  apply  a  special  measure  derogating  from  Article  287  of  Directive  2006/112/EC  on  the 
common system of value added tax (OJ L 30, 28.1.2021, p. 2). 
Council  Implementing  Decision  (EU)  2020/1661  of  3  November  2020  amending  Implementing 
Decision (EU) 2017/1768 authorising the Republic of Croatia to introduce a special measure derogating 
from  Article  287  of  Directive  2006/112/EC  on  the  common  system  of  value  added  tax  (OJ  L  374, 
10.11.2020, p. 4). 
Council  Implementing  Decision  (EU)  2021/753  of  6  May  2021  authorising  Malta  to  apply  a  special 
measure derogating from Article 287 of Directive 2006/112/EC on the common system of value added 
tax, and repealing Implementing Decision (EU) 2018/279 (OJ L 163, 10.5.2021, p. 1). 
Council  Implementing  Decision  (EU)  2022/464  of  21  March  2022  amending  Implementing  Decision 
2013/54/EU  as regards the  authorisation granted to the  Republic of  Slovenia to  continue  to apply the 
special measure derogating from Article 287 of Directive 2006/112/EC on the common system of value 
added tax (OJ L 94, 23.3.2022, p. 4). 

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Derogations from the VAT Directive should always be limited in time so that their effects can 
be  assessed.  In  addition,  the  inclusion  of  an  expiry  date  of  the  special  measure  until  31 
December 2024 is aligned with the requirements of Directive (EU) 2020/285. That directive 
provides  for  1  January  2025  as  the  date  on  which  Member  States  will  have  to  apply  the 
national provisions, which they are required to adopt, to comply with it. 

The proposed measure is therefore consistent with the provisions of the VAT Directive. 

• 

Consistency with other Union policies 

The  Commission  has  been  consistently  stressing  the  need  for  simpler  rules  for  small 
enterprises.  In  this  respect,  the  Commission  adopted  in  March  2020  an  SME  Strategy  for  a 
sustainable  and  digital  Europe22,  where  it  committed  to  continue  to  work  on  reducing  the 
burden on SMEs. The objective to reduce the regulatory burden for SMEs is one of the pillars 
of that strategy. This special measure is in line with such objectives, as far as fiscal rules are 
concerned.  It  is  also  consistent  with  the  2020  Action  Plan  on  fair  and  simple  taxation 
supporting  the  recovery  strategy23,  which  acknowledges  that  tax  compliance  costs  remain 
high in the EU, and that compliance costs are typically substantially higher for small than for 
large companies. 

2. 

• 

LEGAL BASIS, SUBSIDIARITY AND PROPORTIONALITY 

Legal basis 

Article 395 of the VAT Directive. 

• 

Subsidiarity (for non-exclusive competence)  

Considering the provision of the VAT Directive on which it is based, the proposal falls under 
the exclusive competence of the European Union. Hence, the subsidiarity principle does not 
apply. 

• 

Proportionality 

The Decision concerns an authorisation granted to a Member State upon its own request and 
does not constitute any obligation. 

Given  the  limited  scope  of  the  derogation,  the  special  measure  is  proportionate  to  the  aim 
pursued,  i.e.  to  simplify  the  tax  collection  for  small  taxable  persons  and  for  the  tax 
administration. 

• 

Choice of the instrument 

The instrument proposed is a Council Implementing Decision. 

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Council  Implementing  Decision  (EU)  2022/865  of  24  May  2022  authorising  the  Czech  Republic  to 
introduce  a  special  measure  derogating  from  Article  287  of  Directive  2006/112/EC  on  the  common 
system of value added tax (OJ L 151, 2.6.2022, p. 66). 
Council  Implementing  Decision  (EU)  2020/1260  of  4  September  2020  amending  Implementing 
Decision (EU) 2017/1855 authorising Romania to apply a special measure derogating from Article 287 
of Directive 2006/112/EC on the common system of value added tax (OJ L 296, 10.9.2020, p. 1). 
Communication  from  the  Commission  to  the  European  Parliament,  the  Council,  the  European 
Economic  and  Social  Committee  and  the  Committee  of  the  Regions  –  An  SME  Strategy  for  a 
sustainable and digital Europe (COM(2020) 103 final). 
Communication  from the  Commission to the European Parliament and the  Council  –  An  Action Plan 
for fair and simple taxation supporting the Recovery Strategy (COM(2020) 312 final). 

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Under Article 395 of the VAT Directive, a derogation from the common VAT rules is only 
possible upon authorisation by the Council, which is acting unanimously on a proposal from 
the  Commission.  A  Council  Implementing  Decision  is  the  most  suitable  instrument  since  it 
can be addressed to an individual Member State. 

3. 

• 

RESULTS 
CONSULTATIONS AND IMPACT ASSESSMENTS 

EX-POST 

EVALUATIONS, 

OF 

STAKEHOLDER 

Stakeholder consultations 

No stakeholder consultation has been conducted. The present proposal is based on a request 
made by Luxembourg and concerns only this particular Member State. 

• 

Impact assessment 

The proposal for a Council Implementing Decision aims at continuing for another two years a 
simplification measure which removes many of the VAT obligations for businesses operating 
with an annual turnover no higher than EUR 35 000 and therefore has a positive impact on the 
reduction  of  administrative  burden  for  businesses  and  tax  administration  without  a  major 
impact  on  the  total  VAT  revenue.  Because  of  the  narrow  scope  of  the  derogation  and  its 
limited application in time, the impact of the measure will in any case be limited. 

The derogating measure will be optional for taxable persons. Taxable persons will be able to 
opt  for  the  regular  VAT  arrangements  in  accordance  with  Article  290  of  Directive 
2006/112/EC. 

• 

Fundamental rights 

The proposal does not have any consequences for the protection of fundamental rights. 

4. 

BUDGETARY IMPLICATIONS 

Following  entering  into  force  of  Council  Regulation  (EU,  Euratom)  2021/769  of  30  April 
2021  amending  Regulation  (EEC,  Euratom)  No  1553/89  on  the  definitive  uniform 
arrangements for the collection of own resources accruing from value added tax24, there will 
be  no  compensation  calculation  carried  out  by  Luxembourg  as  of  VAT  own  resource 
statement for the financial year 2021 onwards. 

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Council  Regulation (EU, Euratom) 2021/769 of 30 April  2021 amending Regulation (EEC, Euratom) 
No 1553/89 on the definitive uniform arrangements for the collection of own resources accruing from 
value added tax (OJ L 165, 11.5.2021, p. 9).  

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2022/0220 (NLE) 

Proposal for a 

COUNCIL IMPLEMENTING DECISION 

amending Implementing Decision 2013/677/EU authorising Luxembourg to introduce a 
special measure derogating from Article 285 of Directive 2006/112/EC on the common 
system of value added tax 

THE COUNCIL OF THE EUROPEAN UNION, 

Having regard to the Treaty on the Functioning of the European Union,  

Having  regard  to  Council  Directive  2006/112/EC  of  28  November  2006  on  the  common 
system of value added tax1, and in particular Article 395(1) thereof, 

Having regard to the proposal from the European Commission, 

Whereas: 

(1) 

(2) 

(3) 

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Under Article 285 of Directive 2006/112/EC, Member States which have not exercised 
the  option  under  Article  14  of  Second  Council  Directive  67/228/EEC2  are  able  to 
exempt  from  value  added  tax  (‘VAT’)  taxable  persons  whose  annual  turnover  is  no 
higher  than  EUR  5  000,  or  the  equivalent  in  national  currency,  and  may  grant 
graduated tax relief to taxable persons whose annual turnover exceeds the ceiling fixed 
by them for its application.. 
By  Council  Implementing  Decision  2013/677/EU3,  Luxembourg  was  authorised  to 
introduce  a  special  measure  derogating  from  Article  285  of  Directive  2006/112/EC 
(‘the special measure’) to exempt from VAT taxable persons whose annual turnover is 
no higher than EUR 25 000 until 31 December 2016.  

Implementing Decision 2013/677/EU was initially amended by Council Implementing 
Decision (EU) 2017/3194, which authorised Luxembourg to exempt from VAT taxable 
persons  whose  annual  turnover  was  no  higher  than  EUR  30  000  until  31  December 
2019.  It  was  subsequently  amended  by  Council  Implementing  Decision  (EU) 
2019/22105,  authorising  Luxembourg  to  increase  the  threshold  to  EUR  35 000  and 
extend the expiry date of the special measure to 31 December 2022. 

OJ L 347, 11.12.2006, p. 1. 
Second Council Directive 67/228/EEC of 11 April 1967 on the harmonisation of legislation of Member 
States concerning turnover taxes — Structure and procedures for application of the common system of 
value added tax (OJ 71, 14.4.1967, p. 1303). 
Council  Implementing  Decision  2013/677/EU  of  15  November  2013  authorising  Luxembourg  to 
introduce  a  special  measure  derogating  from  Article  285  of  Directive  2006/112/EC  on  the  common 
system of value added tax, OJ L 316, 27.11.2013, p. 33). 
Council Implementing Decision (EU) 2017/319 of 21 February 2017 amending Implementing Decision 
2013/677/EU  authorising  Luxembourg  to  introduce  a  special  measure  derogating  from  Article  285  of 
Directive 2006/112/EC on the common system of value added tax (OJ L 47, 24.2.2017, p. 7). 
Council  Implementing  Decision  (EU)  2019/2210  of  19  December  2019  amending  Implementing 
Decision 2013/677/EU authorising Luxembourg to introduce a special measure derogating from Article 
285  of  Directive  2006/112/EC  on  the  common  system  of  value  added  tax  (OJ  L  332,  23.12.2019,  p. 
155). 

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(4) 

(5) 

(6) 

(7) 

(8) 

(9) 

By letter of 11 March 2022, Luxembourg submitted a request to the Commission for 
an authorisation to continue to apply the special measure until 31 December 2024, the 
date  by  which  Member  States  are  to  transpose  Council  Directive  (EU)  2020/2856 
which lays down simpler VAT rules for small enterprises. That Directive also allows 
Member States to exempt taxable persons whose Member State annual turnover does 
not exceed a threshold of EUR 85 000. 

Pursuant  to  Article  395(2),  second  subparagraph,  of  Directive  2006/112/EC,  the 
Commission transmitted the request made by Luxembourg to the other Member States, 
by  letter  of  7  April  2022.  By  letter  of  8  April  2022,  the  Commission  notified 
Luxembourg that it had all the information necessary for the appraisal of the request. 

The  special  measure  is  in  line  with  Directive  (EU)  2020/285,  which  seeks  to  reduce 
VAT  compliance  costs  for  small  enterprises,  distortions  of  competition  at  both 
national  and  Union  level,  and  the  negative  impact  of  transition  from  exemption  to 
taxation  (the  threshold  effect).  It  also  seeks  to  facilitate  compliance  by  small 
enterprises as well as monitoring by tax authorities. The threshold of EUR 35 000 is 
consistent  with  the  new  threshold  for  exemption  as  laid  down  by  Directive  (EU) 
2020/285. 

The  special  measure  will  remain  optional  for  taxable  persons.  Taxable  persons  may 
still  opt  for  the  normal  VAT  arrangements  pursuant  to  Article  290  of  Directive 
2006/112/EC. 

According  to  information  provided  by  Luxembourg,  the  special  measure  will  have 
only a negligible effect on the overall amount of the tax revenue Luxembourg collects 
at the stage of final consumption. 
Following the entry into force of Council Regulation (EU, Euratom) 2021/7697, there 
will  be  no  compensation  calculation  carried  out  by  Luxembourg  with  regard  to  the 
VAT own resource statement for the financial year 2021 onwards. 

(10)  Given  the  positive  impact  of  the  special  measure  in  simplifying  VAT-related 
obligations by reducing the administrative burden and compliance costs for both small 
enterprises  and  tax  authorities,  and  the  lack  of  any  major  impact  on  the  total  VAT 
revenue generated, Luxembourg should be authorised to apply the special measure for 
a further period. 

(11)  The  authorisation  to  apply  the  special  measure  should  be  limited  in  time.  The  time 
limit should be sufficient to allow for evaluating the effectiveness and appropriateness 
of  the  threshold.  Moreover,  pursuant  to  Article  3(1)  of  Directive  (EU)  2020/285, 
Member States are to adopt and publish, by 31 December 2024, the laws, regulations 
and administrative provisions necessary to comply with Article 1 of that Directive, and 
are  to  apply  those  provisions  from  1  January  2025.  It  is  therefore  appropriate  to 
authorise Luxembourg to apply the special measure until 31 December 2024. 

(12) 

Implementing Decision 2013/677/EU should therefore be amended accordingly, 

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Council  Directive  (EU)  2020/285  of  18  February  2020  amending  Directive  2006/112/EC  on  the 
common system of value added tax as regards the special scheme for small enterprises and Regulation 
(EU)  No  904/2010  as  regards  the  administrative  cooperation  and  exchange  of  information  for  the 
purpose  of  monitoring  the  correct  application  of  the  special  scheme  for  small  enterprises  (OJ  L  62, 
2.3.2020, p. 13). 
Council  Regulation (EU, Euratom) 2021/769 of 30 April  2021 amending Regulation (EEC, Euratom) 
No 1553/89 on the definitive uniform arrangements for the collection of own resources accruing from 
value added tax (OJ L 165, 11.5.2021, p. 9). 

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HAS ADOPTED THIS DECISION:  

Article 1 

Article 2 of Implementing Decision 2013/677/EU is replaced by the following: 

This Decision shall apply from 1 January 2013 until 31 December 2024.’. 

‘Article 2 

This Decision is addressed to the Grand Duchy of Luxembourg. 

Done at Brussels, 

Article 2 

For the Council 
The President 

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