The Luxembourg Administration of Direct Tax has published Circular L.I.R. no. 168bis/1 of 8 January 2021. The Circular concerns the application of the interest deduction limitation rules implemented in line with the EU Anti-Tax Avoidance Directive (ATAD) with effect from 1 January 2019. Under the interest deduction limitation rules, the deduction of net interest expense (borrowing costs) is limited to 30% of EBITDA or a EUR 3 million safe harbor. Excess borrowing costs exceeding the limits m…