After many years of reforms encouraged by the OECD's BEPS
Action plan, it seems as if Luxembourg is now on the home stretch
of the BEPS reform marathon.
In December, the Luxembourg parliament passed the last of the
BEPS-inspired reforms in the pipeline: ATAD 2 and tax dispute
resolution mechanisms. The adoption of the DAC 6 law, which has not
been passed at the time of writing of the present Insights, should
follow very soon. In these Insights, we describe the implications
of the new Luxembourg rules implementing the EU Anti-Tax Avoidance
Directive regarding hybrid mismatches with third countries (ATAD
2). We then provide an overview of the new Luxembourg procedure to
resolve situations of double taxation between Luxembourg and one or
more EU Member States based on the EU Directive on tax dispute
resolution mechanisms. We also present the future new obligations
of Luxembourg intermediaries in relation to the rules on mandatory
automatic exchange of information in the
