Luxembourg has published Circular L.I.R. n° 164ter/1 of 4 March 2020 on the country's controlled foreign company (CFC) rules that were introduced as part of the Law of 21 December 2018 for the implementation of the EU Anti-Tax Avoidance Directive, which generally applies from 1 January 2019 ({News-2018-12-20/A/3-previous coverage}). The Circular includes guidance and examples on the determination of the conditions for a foreign company to be considered a CFC, including the ownership threshold (50%) and low taxation (less than half of the Luxembourg tax), as well as the exemption where the CFC's accounting profits do not exceed EUR 750,000...