On 8 August 2019, Bill of Law 7466 ("Bill") implementing the Anti-Tax Avoidance Directive (EU) 2017/952 on hybrid mismatches ("ATAD2") into Luxembourg domestic law was published. ATAD2 amends Directive (EU) 2016/1164, which had already introduced a first set of rules targeting certain hybrid mismatches between EU Member States ("ATAD1"). ATAD2 extends the scope of ATAD1 hybrid mismatch rules to cover a wider variety of mismatches and mismatches between EU Member States and third countries.
The Bill's content largely reproduces that of ATAD2. The Bill also provides some useful clarifications, notably on the concept of "acting together". It is welcome that the Bill also implements ATAD2's carve-outs. Accordingly, the Bill addresses the four categories of hybrid mismatch arrangements provided for in ATAD2.
More detailed information on the Bill can be found in our related article "Draft Law on ATAD2" published on our website.
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