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

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. This book provides a 360° view on the transformation of the Luxembourg tax environment.