Download or read book Hybrid mismatch rules in Luxembourg written by Legitech and published by . This book was released on 2020-07-07 with total page 336 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Luxembourg Implements ATAD 2 Part 1 written by O.R. Hoor and published by . This book was released on 2019 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: In Part 1 of a two-part article, the author analyses the scope of the new Luxembourg hybrid mismatch rules and the mechanisms for neutralizing hybrid mismatch outcomes.
Download or read book Luxembourg Implements ATAD 2 Part 2 written by O.R. Hoor and published by . This book was released on 2019 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: In Part 2 of a two-part article, the author analyses the scope and mechanism of the Luxembourg reverse hybrid mismatch rules and the cooperation duties of taxpayers with regard to the new hybrid mismatch rules.
Download or read book Luxembourg Adopts EU Anti Tax Avoidance Directive written by P-R. Dukmedjian and published by . This book was released on 2019 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: Luxembourg transposed the OECD and European Union's tax avoidance measures into domestic law in December 2018, addressing hybrid mismatch rules, CFC rules, and interest limitation rules, among others. This article explores the potential impact for taxpayers.
Download or read book Implementation in Luxembourg of the EU Anti Tax Avoidance Directive written by J. Neugebauer and published by . This book was released on 2018 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: The Anti-Tax Avoidance Directive (ATAD) Bill constitutes a comprehensive and coherent implementation of the ATAD I provisions. It includes significant changes in the Luxembourg tax laws which may impact MNCs and international investors. Given that most provisions will enter into force as early as 1 January 2019, investors and taxpayers concerned should check the potential impacts of the ATAD Bill on their activities in Luxembourg and abroad. In addition, given the forthcoming implementation of ATAD II as of 1 January 2020, current operations and future transactions should be reviewed in order to assess the impact of expected anti-hybrid mismatch rules.
Download or read book OECD G20 Base Erosion and Profit Shifting Project Neutralising the Effects of Hybrid Mismatch Arrangements Action 2 2015 Final Report written by OECD and published by OECD Publishing. This book was released on 2015-10-05 with total page 458 pages. Available in PDF, EPUB and Kindle. Book excerpt: Addressing base erosion and profit shifting (BEPS) is a key priority of governments. In 2013, OECD and G20 countries, working together on an equal footing, adopted a 15-point Action Plan to address BEPS. This publication is the final report for Action 2.
Download or read book Employment Law Review written by Erika C Collins and published by Law Business Research Ltd.. This book was released on 2017-04-07 with total page 1263 pages. Available in PDF, EPUB and Kindle. Book excerpt: The Employment Law Review, edited by Erika C Collins of Proskauer Rose LLP, serves as a tool to help legal practitioners and human resources professionals identify issues that present challenges to their clients and companies. As well as in-depth examinations of employment law in 48 jurisdictions, the book provides further general interest chapters covering the variety of employment-related issues that arise during cross-border merger and acquisition transactions, aiding practitioners and human resources professionals who conduct due diligence and provide other employment-related support in connection with cross-border corporate M&A deals. Other chapters deal with global diversity and inclusion initiatives across the globe, social media and mobile device management policies, and the interplay between religion and employment law. Contributors include: Els de Wind, Van Doorne; Annie Elfassi, Loyens Loeff. "e;Excellent publication, very helpful in my day to day work."e; - Mr Frederic Thoral, Head of HR, BNP Paribas"e;Excellent coverage and detail on each country is brilliant."e; - Mr Raani Costelloe, General manager of Legal and Business Affairs, Sony music Entertainment, Australia"e;An excellent resource for in-house counsel for a company with an international footprint."e; - Mr John R Pendergast, Senior Counsel, BASF Corporation, USA"e;It's invaluable to any lawyer dealing with cross-border and privacy-related employment issues and is a cornerstone to my own legal research"e; - Oran Kiazim, Vice President, Global Privacy, SterlingBackcheck, UK
Download or read book Neutralising the Effects of Hybrid Mismatch Arrangements written by Oecd and published by OCDE. This book was released on 2014-09-16 with total page 99 pages. Available in PDF, EPUB and Kindle. Book excerpt: This report sets out recommendations for domestic rules to neutralise the effect of hybrid mismatch arrangements and includes changes to the OECD Model Tax Convention to address such arrangements. Once translated into domestic law, the recommendations in Part 1 of the report will neutralise the effect of cross-border hybrid mismatch arrangements that produce multiple deductions for a single expense or a deduction in one jurisdiction with no corresponding taxation in the other jurisdiction. Part 1 of the report will be supplemented by a commentary, which will explain the recommended rules and illustrate their application with practical examples. Part 2 of the report sets out proposed changes to the Model Convention that will ensure the benefits of tax treaties are only granted to hybrid entities (including dual resident entities) in appropriate cases. Part 2 also considers the interaction between the OECD Model Convention and the domestic law recommendations in Part 1.
Download or read book Cross border Hybrid Mismatch Arrangements in a Post BEPS World U S and EU Perspectives written by O. Grisales-Racini and published by . This book was released on 2017 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: This article examines the impact of the OECD guidance on hybrid mismatch arrangements in the U.K., the Netherlands, Luxembourg and Ireland and reviews the challenges of multi-jurisdictional efforts to implement cross-border harmonization in the context of abusive hybrid mismatch arrangements, particularly for U.S. multinationals.
Download or read book Luxembourg Tax Reform What s Changing in 2019 part 2 written by O.R. Hoor and published by . This book was released on 2019 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: Part 2 of this two-part Insight continues a review of the tax reforms introduced in Luxembourg, with a focus on how they address the anti-hybrid mismatch rules, exit taxation, and other anti-BEPS measures.
Download or read book Transformation of the Luxembourg Tax Environment Towards the Post BEPS Era written by Oliver R. Hoor and published by . This book was released on 2021 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: Over the last years, the Luxembourg tax environment has undergone a comprehensive transformation following the OECD Base Erosion and Profit Shifting ("BEPS") Project and subsequent initiatives at EU level. 00With the transposition of the two Anti-Tax Avoidance Directives (?ATAD? and ?ATAD 2?) and the implementation of other tax measures into Luxembourg tax law, the Grand-Duchy contributed to a level playing field in international taxation. ATAD and ATAD 2 resulted in the implementation of a number of anti-abuse provisions including:0- Interest limitation rules;0- Controlled foreign company (?CFC?) rules;0- Hybrid mismatch rules;0- General Anti-abuse Rule (?GAAR?);0- Exit tax rules .00In addition, the Luxembourg legislator changed in 2019 the definition of permanent establishments (?PE?) and abolished the roll-over relief applicable to conversions of debt instruments into equity. 00This book provides a 360° view on the transformation of the Luxembourg tax environment.
Download or read book Alternative Investments in Luxembourg A Comprehensive Tax Guide written by Oliver R. Hoor and published by . This book was released on 2021 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: Over the last few decades, Luxembourg has emerged to the location of choice for alternative investments (private equity, private debt, real estate, infrastructure, etc.) in and throughout Europe. The attractiveness of Luxembourg is linked to a host of factors which have made it an essential part of the global financial architecture. 0These factors include a flexible and diverse legal, regulatory and tax framework, investor and lender familiarity with the jurisdiction, the availability of a qualified, multilingual workforce, the existence of a deep pool of experienced advisers and service providers, a large tax treaty network, an investor-friendly business and legal environment, and political stability, to name a few. 0However, while the Grand-Duchy continues to be attractive for international investors and asset managers, the climate in the international tax arena has changed significantly over the last few years. The OECD Base Erosion and Project Shifting (?BEPS?) Project and related initiatives at EU level resulted in substantial tax law changes across Europe and the rest of the world. 0In the European Union, the transposition of two Anti-Tax Avoidance Directives (?ATAD? and ?ATAD 2?) resulted in the implementation of a number of anti-abuse provisions such as the interest limitation rules, the hybrid mismatch rules and a general anti-abuse rule. 0While substance was always an important topic for Luxembourg companies which are frequently involved in cross-border investment and business activities, the focus on economic substance only increased throughout and following the OECD BEPS Project. Therefore, it is crucial to equip Luxembourg companies with an appropriate level of substance. 0Another important development concerns transfer pricing which has become the hot topic in Luxembourg.
Download or read book The Mandatory Disclosure Regime in Luxembourg A Practical Guide written by Oliver R. Hoor and published by . This book was released on 2020 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: The mandatory disclosure regime (?MDR?) requires intermediaries (that are tax advisers and other service providers) to report certain cross-border arrangements to the Luxembourg tax authorities. The MDR is the transposition of DAC 6 that required the implementation of the MDR in all European Member States. 00The MDR operates through a system of hallmarks that may trigger reporting obligations and the main benefit test (?MBT?) that functions as a threshold requirement for many of these hallmarks. As such, the MBT should filter out irrelevant reporting and enhance the usefulness of the information collected because the focus will be on arrangements that have a higher probability of truly presenting a risk of tax avoidance. When applicable, the MBT sets a fairly high threshold for reporting under the MDR. 00It can be anticipated that potential reporting obligations under the MDR will become an integral part of each and every tax analysis and should be considered at an early stage. This will ensure that taxpayers can take into account potential reporting obligations in their decision as to whether or not to implement a certain cross-border arrangement. This on its own will achieve the desired deterrence effect as both intermediaries and taxpayers will need to carefully consider potential reporting obligations. 0The MDR introduces some vague definitions and concepts that can, at times, make it difficult for practitioners to determine whether or not a specific cross-border arrangement is reportable. However, for taxpayers it is important that the reporting in Luxembourg and across Europe is as consistent as possible. Therefore, intermediaries and taxpayers have to allocate appropriate resources to ensure compliance with the MDR.00This book is a practical guide that analyses the scope and limits of the MDR in Luxembourg.
Download or read book International Convergence of Capital Measurement and Capital Standards written by and published by Lulu.com. This book was released on 2004 with total page 294 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Action Plan on Base Erosion and Profit Shifting written by OECD and published by OECD Publishing. This book was released on 2013-07-19 with total page 44 pages. Available in PDF, EPUB and Kindle. Book excerpt: This action plan, created in response to a request by the G20, identifies a set of domestic and international actions to address the problems of base erosion and profit sharing.
Download or read book Guide to the Luxembourg Corporate Tax Return written by Maude Bologne and published by . This book was released on 2022 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Combating Tax Avoidance in the EU written by José Manuel Almudí Cid and published by Kluwer Law International B.V.. This book was released on 2018-12-20 with total page 656 pages. Available in PDF, EPUB and Kindle. Book excerpt: Following each Member State's need to rebuild a strong and stable economy after the 2007 financial crisis, the European Union (EU) has developed a robust new transparency framework with binding anti-abuse measures and stronger instruments to challenge external threats of base erosion. This is the first and only book to provide a complete detailed analysis of the Anti-Tax Avoidance Package and other recent and ongoing European actions taken in direct taxation. With contributions from both prominent tax academics and Spain's delegates to the European meetings where these rules are debated and promulgated, the book covers such issues and topics as the following: – the development of the EU Strategy towards Aggressive Tax Planning; – recent tax-related jurisprudence of the European Court of Justice; – the Anti-Tax Avoidance Directive; – tax treaties and non-tax treaties with tax consequences both between Member States and between Member States and third countries; – code of conduct for business taxation; – automatic exchange of information; – country-by-country reporting; – arbitration in tax matters; – external strategy for effective taxation regarding non-EU countries; – competition and state aid developments in direct taxation; – the Common Consolidated Tax Base; and – digital significant presence and permanent establishment. As the EU pursues its ambitious tax agenda, taxation's contribution to EU growth and competitiveness and its part in relations with the rest of the world will come into ever clearer focus. In addition to its insights into these trends, the book's unparalleled practical information and analysis will be of great value to tax practitioners dealing with investment analysis, tax planning schemes, and other features of the current international tax landscape.
