Luxembourg: Tax Authorities issue Circulars on Intra-group Financing Activities

Real Estate Tax Services Newsalert ()

In a Circular (LIR no. 164/2) issued by the Luxembourg direct tax authorities and made public on 28 January 2011, guidance was given on the practices that the Luxembourg tax authorities will henceforth apply in reviewing the tax treatment of companies carrying out intra-group financing activities. The Circular focuses strongly on transfer pricing considerations and on the level of substance needed before the Luxembourg tax authorities will give an advance tax agreement to such a company.

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