Legitimate expectations in Luxembourg tax law - A study of administrative circulars and tax rulings issued by the Luxembourg tax authorities

This thesis analyzes the status of tax circulars and tax rulings in domestic law. More precisely, by first studying the status of each of these administrative interpretative acts, I then investigate their enforceability before domestic courts and enquire to what extent unlawful circulars and contra legem rulings can be relied upon by virtue of the principle of legitimate expectations. After extracting a series of shortcomings in the protection of taxpayers who rely on such administrative interpretative acts, I then, articulate from a normative perspective, what I claim to be the appropriate level of protection for contra legem circulars and advance decisions in the Luxembourg legal order.