Luxembourg tax authorities have issued new guidance clarifying the application of the so-called “CIV carve-out” within the framework of the reverse hybrid rules. This latest interpretation aims to provide much-needed clarity for funds and corporate taxpayers navigating the complex landscape of hybrid mismatch arrangements under Luxembourg tax law. The clarification, highlighted in a recent update by law firm Stibbe, addresses key uncertainties surrounding the classification and tax treatment of Collective Investment Vehicles (CIVs), offering important insights for both domestic and international investors.
Luxembourg Tax Authorities Provide Clarity on CIV Carve Out Implications
The recent guidance from Luxembourg tax authorities offers much-needed clarity on the application of the “CIV carve-out” in the context of reverse hybrid rules. This development addresses longstanding uncertainties surrounding collective investment vehicles (CIVs) and their classification for tax…
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Author : Noah Rodriguez
Publish date : 2025-08-26 23:25:00
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