Luxembourg Budget Law 2023 enacts clarification to Reverse Hybrid Entity Rule

Luxembourg’s Budget Law 2023 clarifies that the Reverse Hybrid Entity Rule only applies where the non-taxation of net income results from a difference of classification and that only the share of the net income attributable to associated enterprises triggering the application of the Reverse Hybrid Entity Rule is subject to corporate tax at the level of the Luxembourg entity or arrangement.

The Law also excludes fossil gas and nuclear energy investments from the benefit of the reduced subscription…