On December 18th, the Luxembourg draft law implementing the EU Anti-Tax Avoidance Directive (“ATAD”) was passed by the Parliament. While the main purpose of the draft law is to implement ATAD, it is worth mentioning that it also includes two additional BEPS -related tax law changes aiming at removing potential double non -taxation situations. Over the legislative process, the draft law has only been subject to few amendments and work remains to be done in order to clarify some practical implications and the impact of some of the new measures on existing tax law.This tax alert provides an overview of the different tax measures which, for most of them, will become applicable as from 1 January 2019.

The aim of ATAD is to implement at EU level the BEPS (Base Erosion and Profit Shifting) recommendations made by the OECD and the G20 in October 2015.