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Clifford Chance

Clifford Chance

Briefings

Reverse hybrid rule: guidance issued by the Luxembourg tax administration

19 June 2023

On 9 June 2023, the Luxembourg tax administration issued a circular L.I.R n° 168quater/1 (the "Circular") providing some guidance on the application of the reverse hybrid rule, in particular on the computation of the taxable result of a reverse hybrid entity and the tax due by such taxpayer. This is the first Circular issued by the Luxembourg tax administration regarding the application of ATAD 2.

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