Clifford Chance
Luxembourg tax authorities release circular providing administrative guidance on application of interest limitation rule
26 January 2021
On 8 January 2021, the Luxembourg tax authorities issued Circular L.I.R. n°168bis/1 providing clarifications on the Interest Limitation Rule as introduced by the Anti-Tax Avoidance Directive (ATAD I) adopted in July 2016 and transposed in December 2018 by Article 168bis of the Luxembourg income tax law (the "LITL"). The new Circular, largely based on the commentaries to the bill of law implementing the ATAD I, describes the Luxembourg tax authorities' interpretation and practical approach towards the Interest Limitation Rule
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