ATAD

• Overview on the various actions combatting tax avoidance (From BEPS to ATAD 2).
• Identify the new rules and regulations regarding TAX Avoidance (draft law transposing ATAD 2).
• Evaluate the impact of ATAD 2 on the Luxembourg Market.
• Understand the interactions of ATAD with DAC6, AML Tax.

From BEPS to ATAD 2: Understand the various actions combatting tax avoidance

• Overview of the measures implemented by BEPS.
• Master the content and the purpose of the Law of 21 December 2018 implementing the European union anti-tax avoidance directive.
• Identify the amendments set by the new law to the tax framework.
• Comprehend the new ATAD 2 directive and the Luxembourg draft law relating to anti-tax-avoidance.

Delineate the scope of the law

• Identify the entities subject to corporation tax within the territory of the member state of the EU and their subsidiaries established in a foreign country.
• Recognize the terms and conditions applied to multinational companies.
• Perceive the rules for defining a controlled foreign company (according to the type and the level of control) and under which conditions these companies are subject to the ATAD obligations.

Comprehend the measures established by ATAD

Measures:

• Deduction of interests.
• Exit Tax.
• The general anti-abuse clause.
• Rules governing controlled companies.
• Rules regarding certain hybrid arrangements.

New regulations relating to the transfer of the registered office.
Ratification of “multilateral instrument” (MLI).

Identify the amendments made by the Luxembourg’s draft law implementing the ATAD 2 directive

• Perceive the content and the aim of ATAD 2 directive
• Define the scope of ATAD 2
• Interpret the amendments made to the law of 21 December 2018

Evaluate the impact of ATAD on the Luxembourg financial place

Case study

Attestation de participation