In this edition of the Maples Group Tax Update, we examine a number of current Irish, Luxembourg and international tax issues:
- Ireland and Luxembourg are implementing significant changes to their national tax regimes under the EU Anti-Tax Avoidance Directive ("ATAD")
- We examine the introduction of anti-hybrid legislation, an interest limitation cap, controlled foreign company ("CFC") rules and an exit tax under ATAD
- We also examine the OECD Multilateral Instrument ("MLI") which is updating tax treaties around the world, most significantly introducing a "principal purpose test" for treaty eligibility
- We give our view on the recent important European Court of Justice caselaw on beneficial ownership in the context of European investment structures
Read the full update here.