Glossary of abbreviations

DAC6

Sixth Directive on Administrative Cooperation

OECD

Organisation for Economic Co-operation and Development

BEPS

Base Erosion and Profit Shifting

CRS

Common Reporting Standard

HMRC

(UK) Her Majesty’s Revenue and Customs

FTA

French tax authorities

Art.

Article

LTA

Luxembourg tax authorities

EU

European Union

ATAD

Anti-Tax Avoidance Directive

FTC

Foreign Tax Credit

ECJ

Court of Justice of the European Union

CFC

Controlled foreign corporation

MDR

Model Mandatory Disclosure Rules for CRS Avoidance Arrangements and Opaque Offshore Structures (2018)

FATF3

Financial Action Task Force 3

APA

Advanced pricing agreements

HTVI

Hard-to-value intangibles

CCA

Capital cost allowance

EBIT

Earnings before interest and taxes

ACD

(Luxembourg) Administration des Contributions Directes

PIT

Personal Income Tax

CIT

Corporate Income Tax

TCLT

Tax on Civil Law Transactions