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Too Bad To Be True – Code §§267a And 894(C) Signal The End For Cross Border Hybrids - Withholding Tax - Vimarsana News

Too Bad To Be True – Code §§267a And 894(C) Signal The End For Cross Border Hybrids - Withholding Tax

If you are a tax professional, you know your client is in a pickle if a tax provision disallows a deduction and another provision subjects the corresponding income to U.S. tax.

Source: mondaq.com
Clarifications on the Luxembourg reverse hybrid mismatch rule - Vimarsana News

Clarifications on the Luxembourg reverse hybrid mismatch rule

On 23 December 2022, the Luxembourg Parliament adopted bill n°8080 related to the budget for 2023 (the "Budget Law 2023" - see our newsflash on the…

Important Change to Luxembourg's Reverse Hybrid Rule - Vimarsana News

Important Change to Luxembourg's Reverse Hybrid Rule

Following the EU Anti Tax Avoidance Directive II (“ATAD II“) coming into force, since 2020 EU Member States have been required to implement into…