20
Jun
By Loyens and Loeff
The bill of law to implement the provisions of the EU Directive 2016/1164 on anti-tax avoidance (ATAD) in Luxembourg law was made available on 20 June 2018. Subject to parliamentary approval, Luxembourg will introduce controlled foreign corporation (CFC), interest deduction limitation and anti-hybrid rules.
It will also modify its existing general anti-abuse rule and, exit tax provisions. Additionally, Luxembourg will change its interpretation of the permanent establishment concept to avoid mismatches and will abrogate the existing roll-over...