The Luxembourg Parliament is considering a draft bill submitted on 8 August 2019 for the implementation of the expanded hybrid mismatch rules of the EU Anti-tax Avoidance Directive as amended (ATAD2). Luxembourg already implemented the initial hybrid mismatch rules of ATAD1 with effect from 1 January 2019 for mismatches involving EU Member States.
Under the draft bill, the hybrid mismatch rules are extended to third (non-EU) countries, and additional rules are introduced in relation to hybri…