The implementation of ATAD in Luxembourg

Briefing 28032019
27/09/2018

The implementation of ATAD in Luxembourg: What will be the impact on Alternative investments and Multinational Group?

On 20 june 2018, the Luxembourg legislator released the draft law for the implementation of the EU Anti-Tax Avoidance Directive ("ATAD"). ATAD provides for several measures targeting Base Erosion and Profit Shifting ("BEPS") with quite a numbre of implementation options. However, did Luxembourg male the right choices? What will be the impact on Alternative Investments and Multinational Groups? And, are there solutions to manage the impact of these tax measures on existing and new investments?

Our agenda will include:

1. The OECD BEPS Project and ATAD

2. Analysing the draft bill

Interest deduction limitation rule; Controlled Foreign Company (CFC) rule;
General Anti-Abuse Rule (GAAR); Anti-hybrid mismatch rule; Exit taxation;
Definition of permanent establishment under Luxembourg tax law;
Changes to the roll-over relief

3. Impact analysis and potential solutions

4. The way forward

 

ATOZ Speaker