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Luxembourg Draft Budget Law 2023 clarifies Reverse Hybrid Entity Rule

17 October 2022

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Tax Alerts, Legislation & Policy, Na...

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Luxembourg, European Union

Luxembourg’s Draft Budget Law clarifies application of the Reverse Hybrid Entity Rule and provides that it will not apply to the extent the nonresident investor in such entity benefits from a subjective tax exemption in its jurisdiction of residence.If adopted, this clarification will take effect as from tax year 2022 when the Reverse Hybrid Entity Rule applies for the first time.Executive summaryOn 14 October 2022, Luxembourg’s Minister of Finance submitted the 2023 draft budget law (Draft Budget Law) to Parliament.In addition to the extension for filing the annual corporate income, municipal business and net wealth tax returns from currently 31...