ATAD 2 Luxembourg: Reverse Hybrid Mismatches and the CIV Rule

Luxembourg's reverse hybrid mismatch rule under ATAD 2 has long been one of the jurisdiction's most complex tax puzzles, particularly when it comes to the collective investment vehicle carve-out.   Has the uncertainty finally been resolved? And what do fund managers and tax advisers operating in Luxembourg need to understand now?  Johanna Tschurtschenthaler, counsel in A&O Shearman's Tax practice, and Chiara Wolf, associate in Tax, return to this topic to bring clarity to the CIV carve-out, walking through the rule's mechanics, the issues that have made it so difficult to apply in practice, and what the current state of play means for structures in scope.