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By Stéphanie YIOLITOU, Senior Associate, Allen Overy Luxembourg
Good ATAD 2 news come to those who wait isn’t quite how the proverb goes, but it does accurately convey the feeling in the Luxembourg funds sector with respect to the recent change to the reverse hybrid entity rule introduced by the Luxembourg budget law of 2023.
The Luxembourg law transposing Council Directive (EU) 2017/952 of 29 May 2017 amending Directive (EU) 2016/1164 as regards hybrid mismatches with third countries (also known as ATAD 2) came into force on 1 January 2020, with the exception of one rule – the reverse hybrid entity rule, which has only been applicable since 1 January 2022.
The aim of the reverse hybrid entity rule is to avoid...
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