ARTICLE · 18 JUNE 2022

ATAD 3 Amendments: Are You Ready For The Changes?

CMS Luxembourg

Explore more from CMS Luxembourg

On 12 May 2022, the reporter of the Committee on Economic and Monetary Affairs of the European Parliament (ECON) published its draft report.

LuxembourgTax

Frédéric Feyten

Alejandro Dominguez

Delphine Danhoui

Author LinkedIn connections

Background

On 12 May 2022, the reporter of the Committee on Economic and Monetary Affairs of the European Parliament (ECON) published its draft report (the Draft Report) with proposed amendments to the initial proposal (published in December 2021) for a Council directive laying down rules to prevent the misuse of shell entities for tax purposes and amending Directive 2011/16/EU (ATAD III or the ATAD III Proposal).

We refer to our previous article on the ATAD III Proposal for further background.

The Draft Report has three main objectives:

the safeguard of taxpayers' rights, in particular in relation to privacy and data protection,
the protection of a level playing field for EU companies while ensuring fair taxation; and

We operate a free-to-view policy, asking only that you register in order to read all of our content. Please login or register to view the rest of this article.

Register for freeORLog in

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

Related Articles

The EU Updates Its List Of Non-Cooperative Tax Jurisdictions: Two Jurisdictions Removed

Atoz Tax Advisers

Luxembourg’s 2027 Budget Bill Proposes Corporate Tax Cuts And Changes To Capital Gains And Loss Carryforwards

Goodwin Procter LLP

Luxembourg Draft Budget 2027: Key Tax Measures For Businesses, Investors And Employers

Atoz Tax Advisers

Luxembourg Budget 2027– Proposed Tax Measures

Luxembourg Budget 2027: Key Tax Measures For Businesses

Legal Intelligence Newsletters: sign up for the latest legal and regulatory news on your chosen topics

Read more about

Tax
- Tax Treaties
- Tax Authorities

Related Comparative Guides

Comparative Guide

Tax Disputes

Comparative Guide

Tax

See more popular content from

Tax

EU Tax Omnibus Package: Key Changes For Europe And Luxembourg

The European Commission's Omnibus proposal seeks to fundamentally reshape the EU's direct taxation framework by removing shareholding thresholds for dividend exemptions, eliminating prior authorization procedures, and harmonizing interest limitation rules across member states. This comprehensive reform promises to streamline cross-border investment structures while raising critical questions about the treatment of alternative investment funds and pension institutions under the new regime.

Luxembourg Budget 2027: Key Tax Measures

On 7 October 2026, the Luxembourg Government filed bill of law No. 8800 concerning the State budget for 2027 (the “Bill”) with the Chamber of Deputies. Alongside the budget itself, the Bill introduces a package of tax measures designed to increase Luxembourg’s tax competitiveness and support businesses, most of which would apply from tax year 2027.

ECOFIN Council Reaches An Agreement On DAC8

At yesterday's ECOFIN meeting, the EU Council agreed on a general approach regarding foreseen amendments to the directive on administrative cooperation in the area of taxation.

Atoz Tax Advisers

VAT Liability Of Online Platforms

The CJEU confirmed the lawfulness of the liability of online platforms to collect VAT on total amounts due on electronic services in the recent Fenix case (C-695/20, 28 February 2023).

Arendt & Medernach

2026 Luxembourg Budget Announced | Tax Measures To Come

On 8 October 2025, the Luxembourg Minister of Finance presented the 2026 budget (the "Budget Law") oriented towards growth and social cohesion.

Luxembourg’s 2027 Budget Bill Proposes Corporate Tax Cuts And Changes To Capital Gains And Loss Carryforwards

Luxembourg's proposed 2027 budget law introduces significant corporate tax reforms, including a 1% reduction in corporate income tax rates that would lower the maximum aggregate tax burden in Luxembourg City to 22.80%. The Bill also extends the holding period for speculative gains on movable assets from six to twelve months and eliminates the 17-year limit on tax loss carryforwards, measures designed to enhance Luxembourg's competitiveness while encouraging longer-term investment strategies.

Goodwin Procter LLP

Form Over Substance: Why The Luxembourg Tribunal's Share Premium Ruling Cannot Stand

The Administrative Court of Luxembourg has issued significant rulings on the qualification of interest-free loans and the use of corporate tax losses in relation to abuse of law concepts. These decisions provide crucial clarity for corporate tax planning and compliance strategies in Luxembourg.

Atoz Tax Advisers

Luxembourg Budget 2027: Key Tax Measures For Businesses

Luxembourg's Finance Minister has unveiled a draft budget for 2027 that includes significant tax reforms affecting businesses and investors. The proposed changes include a reduction in corporate income tax rates, the removal of time limits on loss carryforwards, and enhanced investment tax credits for digitalisation and green projects. However, the extension of the speculation period for capital gains from six to twelve months will require careful consideration by fund managers and investors planning asset

EU Commission Closes State Aid Investigations Into Amazon, Starbucks And Fiat Tax Rulings

Today, the European Commission has closed three in-depth State aid investigations into transfer pricing tax rulings granted by Luxembourg to Fiat and Amazon...

European UnionTax

ELVINGER HOSS PRUSSEN, société anonyme

ATOZ Insights - May 2025

As spring is upon us, the time has come to present our latest edition of our Insights, highlighting recent developments from the Grand Duchy, at European level, and in the Middle East over the past few months.

Atoz Tax Advisers