Transformation of the Luxembourg tax environment : towards the post-BEPS era

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Over the last years, the Luxembourg tax environment has undergone a comprehensive transformation following the OECD Base Erosion and Profit Shifting ("BEPS") Project and subsequent initiatives at EU level.
With the transposition of the two Anti-Tax Avoidance Directives (?ATAD? and ?ATAD 2?) and the implementation of other tax measures into Luxembourg tax law, the Grand-Duchy contributed to a level playing field in international taxation. ATAD and ATAD 2 resulted in the implementation of a number of anti-abuse provisions including:

- Interest limitation rules - Controlled foreign company (?CFC?) rules.
- Hybrid mismatch rules.
- General Anti-abuse Rule (?GAAR?).
- Exit tax rules.

In addition, the Luxembourg legislator changed in 2019 the definition of permanent establishments (?PE?) and abolished the roll-over relief applicable to conversions of debt instruments into equity.