The “Split-Status” Era: Luxembourg’s Anti-Hybrid Rules and Pillar Two in Light of the OECD’s Side-by-Side Package – Part 2

This two-part article explores the foundational transformation of Luxembourg’s anti-hybrid regime (articles 168ter and 168quater of the Luxembourg Income Tax Law following the release of the OECD’s Side-by-Side (SbS) Package on 5 January 2026 and its interaction with the EU Minimum Taxation Directive (2022/2523). The article analyses the transition from a “neutralization-only” model, focused on denying domestic deductions, to a “Qualified Inclusion” framework that integrates the US Global Intangible Low-Taxed Income (GILTI)/Net Controlled Foreign Corporation Tested Income (NCTI) into the Luxembourg tax perimeter. Part 1, which was published in European Taxation 7 (2026), detailed the emergence of the 2026 “Cascade of Taxation”, setting the conceptual stage for a rigorous eight-step methodology. Part 2 outlines a proposed DAC9 reporting framework.

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Publication Details

Journal
European Taxation
Published
2026-07-27
DOI
https://doi.org/10.59403/gc7meq
Primary Topic
Corporate Taxation and Avoidance
Type
article
Field-Weighted Citation Impact
0.00
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article

The “Split-Status” Era: Luxembourg’s Anti-Hybrid Rules and Pillar Two in Light of the OECD’s Side-by-Side Package – Part 2

Konstantia-Angeliki Tampakoudi
European Taxation
Corporate Taxation and Avoidance
article

The “Split-Status” Era: Luxembourg’s Anti-Hybrid Rules and Pillar Two in Light of the OECD’s Side-by-Side Package – Part 2

Konstantia-Angeliki Tampakoudi
article en

Abstract

This two-part article explores the foundational transformation of Luxembourg’s anti-hybrid regime (articles 168ter and 168quater of the Luxembourg Income Tax Law following the release of the OECD’s Side-by-Side (SbS) Package on 5 January 2026 and its interaction with the EU Minimum Taxation Directive (2022/2523). The article analyses the transition from a “neutralization-only” model, focused on denying domestic deductions, to a “Qualified Inclusion” framework that integrates the US Global Intangible Low-Taxed Income (GILTI)/Net Controlled Foreign Corporation Tested Income (NCTI) into the Luxembourg tax perimeter. Part 1, which was published in European Taxation 7 (2026), detailed the emergence of the 2026 “Cascade of Taxation”, setting the conceptual stage for a rigorous eight-step methodology. Part 2 outlines a proposed DAC9 reporting framework.

European TaxationVol. 66(8)
Reduced inequalities
Openalex Percentile: Top 3%
Corporate Taxation and Avoidance
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