On 1 January 2020, the Luxembourg legislator transposed the Anti-Tax Avoidance Directive 2 (ATAD 2) into Luxembourg Tax Law. A new version of Article 168ter of the Luxembourg Income Tax Law (LITL) now provides for A comprehensive framework to tackle Hybrid mismatches In A mere EU context and In transactions involving third countries.
Hybrid mismatches typically originate from A different Tax treatment of an entity, A permanent establishment or A financial instrument under the laws of two or more jurisdictions and may result In deduction without inclusion or double deduction outcomes. In general, the Hybrid mismatch rules target Hybrid mismatches between associated enterprises, structured arrangements between third parties, imported Hybrid mismatches and Tax residency mismatches.
At the same time, the Hybrid mismatch rules should not create economic double taxation. This is ensured through A number of carve-outs and limitations that discharge the application of the Hybrid mismatch rules (for example, timing differences, inclusion of the payment At the level of any payee, Tax exempt status of the investor, transfer pricing adjustments).
As the new rules apply As from 1 January 2020, taxpayers have to urgently analyse existing investment structures In order to detect potential Hybrid mismatches and to implement, where necessary, structure alignments before year-end.
This conference aims At providing participants with A clear overview of the new Hybrid mismatch rules, analysing how these rules may impact Alternative Investments and multinational groups In Luxembourg and considering opportunities to manage adverse Tax consequences In practice.
intervenants:
Fanny Bueb, Tax Director, ATOZ Tax advisers
Oliver R. Hoor, Tax Partner, ATOZ Tax advisers
Andreas Medler, Tax Principal, ATOZ Tax advisers
Hôtel Novotel Luxembourg Kirchberg
6 Rue du Fort Niedergruenewald
2226 Luxembourg
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