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By Christophe De SUTTER, Partner Peter KOVACIK, Senior Manager Deloitte Tax Consulting
As a part of the transposition of the EU Anti-Tax Avoidance Directive (“EU ATAD 1” or “Directive”) into its national legislation, Luxembourg has introduced controlled foreign company (“CFC”) rules. The rules are completely new to the Luxembourg tax system and are effective to Luxembourg taxpayers as from their financial years starting on or after January 1, 2019 onwards. In order to transpose these rules, a new Article 164ter LITL has been introduced into the Luxembourg Income Tax Law of 4 December 1967 (“LITL”).
The CFC rules under the EU ATAD 1 have been inspired by Action 3 of the OECD Plan...
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