On 8 August 2019, the Luxembourg Government filed with Parliament Bill of Law n°7466 implementing into domestic law council directive (EU) 2017/952 of 29 may 2017 (“ATAD II”).
The proposed measures are generally in line with the provisions of ATAD II and should apply as from 1 January 2020 except for the rules on reverse hybrids which should apply as from 1 January 2022.
The new measures are expected to have a significant impact on Luxembourg corporate taxpayers having cross-border operations. Specific measures have however been introduced to address unintended consequences for investment funds. In particular, the acting together concept should not apply to an investor that holds directly or indirectly less than 10% in the interest of the fund and which is entitled to less than 10% of the profits of this fund. In addition, most collective investment funds should be excluded from the reverse hybrid rule.
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