The first part of this publication provided an overview of the controlled foreign corporation (“CFC”) regime introduced under Directive (UE) 2016/1164 of 12 July 2016 laying down rules against tax avoidance practices that directly affect the functioning of the internal market (the so-called Anti-Tax Avoidance Directive (the “ATAD”)).

This constitutes the second part, dealing with the sensitive matter of the potential interactions of the ATAD’s CFC rules with EU law and Luxembourg’s double tax treaties.