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By Oliver R. HOOR (picture), Fanny BUEB and Samantha SCHMITZ-MERLE, Atoz *
On 11 March 2016, the Luxembourg Gover-nment approved a draft law which is meant to implement EU Directive 2015/2376 that foresees the automatic exchange of tax rulings within the EU. The draft law has been presented to Parliament on 22 March 2016 and should be adopted soon. This Article provides for an overview of the new rules and analyses the potential impact on the Luxembourg ruling practice.
1. Introduction
Advance tax rulings(1) and Advance Pricing Agree-ments (“APAs”)(2) provide advance certainty to international investors, multinational groups and other taxpayers on how the Luxembourg tax authorities will apply domestic tax law and tax treaty law to...
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