Luxembourg’s Reverse Hybrid Entity Rule effective as from tax year 2022

Executive summary

As from tax year 2022, Luxembourg’s Reverse Hybrid Entity Rule introduced by law of 20 December 2019 implementing Council Directive (EU) 2017/952 of 29 May 2017 amending Directive (EU) 2016/1164 (ATAD) regarding hybrid mismatches with third countries (ATAD II) will apply.

Companies with a non-calendar financial year may already be subject to this rule with respect to their financial year that started during calendar year 2021.

This Alert summarizes the key provisions of the Revers…