On 8 August, the draft law (the "draft law")
implementing the EU Directive 2017/952 of 29 May 2017 ("ATAD
2") amending Directive (EU) 2016/1164 laying down rules
against tax avoidance practices that directly affect the
functioning of the internal market (the so-called
Anti-Tax-Avoidance-Directive, "ATAD") was presented to
Parliament. ATAD already included measures dealing with hybrid
mismatches in an EU context, which have applied in Luxembourg since
1 January 2019 based on Article 168ter of the Income Tax Law. ATAD
2 replaces these rules and extends their scope, notably to
transactions involving non-EU countries.
In this ATOZ Alert, we give an overview of the new measures
which will enter into force as from 1 January 2020 (apart from the
measure on "reverse hybrid mismatches", which will apply
as from 2022).
