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.

CONTACTS

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Andrew Quinn

Partner

+353 1 619 2038

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William Fogarty

Partner

+353 1 619 2730

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Lynn Cramer

Partner

+353 1 619 2066

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David Burke

Of Counsel

+353 1 619 2779

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James O'Neal

Principal

+352 28 55 12 43

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