These new rules will mainly target multinational corporate groups engaged in cross-border transactions. They include provisions related to interest limitation, exit taxation, a general anti-abuse rule, controlled foreign companies, and intra-EU hybrid mismatches. While some of the bill's measures will only slightly modify the country's existing domestic tax framework, others will bring more significant changes. Notably, the bill contains two additional measures: one modifying Luxembourg's rules on tax neutrality, applicable to the conversion of debts, and another that alters the country's domestic permanent establishment (PE) definition.

For in an in-depth discussion of the bill, see KPMG Insights TaxNewsFlash, "The Luxembourg bill on the ATAD 1 transposition has been issued!"

For more information, contact your KPMG adviser.

Information is current to July 10, 2018. The information contained in this publication is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavour to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act upon such information without appropriate professional advice after a thorough examination of the particular situation. For more information, contact KPMG's National Tax Centre at 416.777.8500