Webinar - The new CFC rules under the ATAD

During this webinar, discover the new rules and how Luxembourg companies can act to minimize the risk of additional taxation

Arendt Seminar

Apr 10, 2019
4:00 PM


Apr 10, 2019
4:30 PM


Luxembourg has introduced ‘controlled foreign company’ rules, effective for financial years starting on or after 1 January 2019. The new rules could attribute the undistributed income of a low-taxed subsidiary to its Luxembourg parent (where it could be taxed at a higher rate). They will apply where ‘non-genuine arrangements’ have been put in place ‘mainly’ for the purpose of obtaining a tax advantage, as indicated where a Luxembourg-resident company manages the important activities of its low-taxed subsidiary.

Danny Beeton, the senior economist in Arendt’s transfer pricing team, will explain the new rules and how Luxembourg companies can act to minimize the risk of additional taxation.



Related Content

Danny Beeton

Danny Beeton is Of Counsel in the Tax Law practice of Arendt & Medernach where he is the senior economist in the Transfer Pricing practice. He advises clients on the determination of arm's length prices for all types of related party transactions, including goods, services and intellectual property, but with a special focus on financial transactions such as loans, guarantees, group treasury policies and asset management fees. Danny's assistance is sought in the context of transfer pricing compliance and reporting, controversy and planning, and he has provided expert reports in the context of litigation. Danny also brings his economics skills to bear in EU state aid matters and in giving gene...

Discover the Author