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By Antoine DUPUIS Andreas MEDLER, ATOZ Tax Advisers *
On 8 January 2021, the Luxembourg tax authorities issued a new Circular n° 168bis/1 (the “Circular”) in order to provide guidance on the interpretation of the interest deduction limitation rules (IDLR) laid down in Article 168bis of the Luxembourg income tax law (LITL) (through which the Council Directive (EU) 2016/1164 of 12 July 2016 laying down rules against tax avoidance practices (ATAD 1) has been transposed into Luxembourg law).
The IDLR have been applicable since 1 January 2019 and shall be interpreted according to the Circular for all tax years from 2019 (the Circular merely has clarifying character with regard to the interpretation of the existing legal provisions)...
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