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By Orianne WAJNBERG, Senior Manager Cross Border Tax Christophe De SUTTER, Partner Cross Border Tax, Deloitte Luxembourg
On 18 December 2018, the Luxembourg Parliament voted on the long awaited Bill n°7318 (“Bill”) transposing the Anti-Tax Avoidance Directive (“ATAD 1” or “Directive”) into Luxembourg law. It entered into effect from 1 January 2019 (applicable to fiscal years starting on or after 1 January 2019). Among other new measures voted upon, a new Article 168bis will be introduced into the Luxembourg Income Tax Law of 4 December 1967 (“LITL”), aiming to transpose the “interest limitation rules” as proposed by the Directive (Article 4 of EU Council Directive (EU) 2016/1164 dated 12 July 2016)(1).
With the global aim of harmonizing...
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