Advocate General (AG) of the Court of Justice of the European Union (CJEU) issued an opinion on 18 June 2026 in Case C-138/24, European Commission v Grand Duchy of Luxembourg, concerning Luxembourg's transposition of the interest limitation rules under Council Directive (EU) 2016/1164 (ATAD). The case concerns Luxembourg's inclusion of securitization special purpose entities within the definition of financial undertakings under Article 168bis of the Luxembourg Income Tax Law, thereby allowin…