Transformation of the Luxembourg tax environment Towards the post-BEPS era - Oliver R. Hoor - Legitech - broché - Etude

DROIT LUXEMBOURGEOISOver 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 rulesIn 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.The Luxembourg transfer pricing regime applicable to companies performing financing activities has alread