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By Oliver R. HOOR and Keith O’DONNELL, Atoz *
On 20 June 2016, the EU Anti-Tax Avoidance Directive(1) (“ATAD”) has been adopted at EU level. The ATAD provides for anti-tax avoidance rules in five specific fields which are meant to be implemented by each EU Member State (“MS”). On 29 May 2017, the EU Council formally adopted a compromise proposal for an EU Directive amending the ATAD (the so-called “ATAD 2”).(2) While the ATAD included already measures dealing with hybrid mismatches in an EU context, ATAD 2 replaces the rules on hybrid mismatches and extends their scope to transactions involving third countries. This is the second of two articles(3) which provide an overview of the main provisions of the Directive and consider how Luxembourg should implement the latter....
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