Luxembourg Submits Draft Law Implementing EU ATAD 2 to Parliament

With some exceptions that are noted below, the provisions of the Draft Law apply only to corporate taxpayers and to PEs of nonresident taxpayers subject to corporate income tax (CIT). [...]in the commentary to the Draft Law, various references are included to relevant paragraphs of the Action 2 repo...

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Bibliographic Details
Published in:Journal of International Taxation 2019-11, Vol.30 (11), p.11-12
Main Authors: Kuipers, Jurjan Wouda, de Matos, Michel Alves, Huysmans, Serge, Picha, Xavier, Pouchard, Alexandre J, Ramirez-Gaston, Andres, Schmitz, Marc
Format: Article
Language:English
Subjects:
EU directives
International taxation
Jurisdiction
Limited partnerships
Nonresidents
Permanent establishment
Provisions
Taxation
Voting rights
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Summary:With some exceptions that are noted below, the provisions of the Draft Law apply only to corporate taxpayers and to PEs of nonresident taxpayers subject to corporate income tax (CIT). [...]in the commentary to the Draft Law, various references are included to relevant paragraphs of the Action 2 report. [...]the following hybrid mismatch arrangements are addressed: * Hybrid entity mismatches: According to the commentaries, it covers undertakings for collective investment in the sense of the Luxembourg law of 17 December 2010, the Specialized Investment Funds (SIFs) in the sense of the Luxembourg law of 13 February 2007, and the Reserved Alternative Investment Funds (RAIFs) in the sense of the Luxembourg law of 23 July 2016.
ISSN:1049-6378