The Luxembourg Tax Authority (“L.T.A.”) has released on the 9th of June2023 a circular LIR N°168 quarter/1 providing guidance on the computation of taxable income of Reverse Hybrid Entities. A new form to be filed electronically for transparent entities together with Frequently Asked Questions guidance on how to fill in such form are now also available on the website of the L.T.A.
This is of great help, as transparent entities incorporated in Luxembourg are, since tax year 2022 and subject to specific conditions, treated as corporate taxpayers and consequently subject Corporate Income Tax in Luxembourg for their income that is neither taxed in Luxembourg nor taxed in another jurisdiction ( Reverse Hybrid Entity).