Transformation of the Luxembourg Tax Environment Towards the Post-BEPS Era

Download or read book Transformation of the Luxembourg Tax Environment Towards the Post-BEPS Era written by Oliver R. Hoor and published by . This book was released on 2021 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: 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. 00With 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:0- Interest limitation rules;0- Controlled foreign company (?CFC?) rules;0- Hybrid mismatch rules;0- General Anti-abuse Rule (?GAAR?);0- Exit tax rules .00In 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. 00This book provides a 360° view on the transformation of the Luxembourg tax environment.