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By Basile FEMELAT, Avocat à la Cour, PwC Legal Luxembourg
The Luxembourg law transposing Council Directive (EU) 2016/1164 of 12 July 2016 laying down rules against tax avoidance practices that directly affect the functioning of the internal market (“ATAD 1”) was recently published in the Luxembourg official gazette (the “Law”). The Law is generally applicable for financial years starting as from 1 January 2019 (with certain tax provisions being applicable as from 2020 only, e.g. exit tax provisions). The Law introduces interest deduction limitation rules that may apply to Luxembourg securitisation vehicles.
1. New rules – interest deductibility limitation
To limit tax avoidance strategies, new rules...
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