18 jan 2017 · On December 27, 2016, the Luxembourg Tax Authorities issued a new Circulaire (the Circular) providing out group financing transactions
pwc-TP-Luxembourg-intra-group-financial-transactions.pdf
27 déc 2016 · guidelines relating to the tax treatment of Luxembourg companies carrying out for instance in a “back-to-back” loan situation as holding
Update-on-the-Luxembourg-Intra-Group-Financing-Tax-Circular.pdf
18 déc 2018 · As such, the interest deduction limitation rule should not impact taxpayers engaged in back-to-back financing
al_luxembourg_atad_dec2018.pdf
A Luxembourg company (LuxCo) receives an interest-free loan ing the taxable income in its corporate tax returns 2 3 The concept of hidden dividend
et_-_luxembourg_reshapes_its_transfer_pricing_landscape_-_april_2015.pdf
1 mar 2021 · Interest deduction in France • Inclusion in Luxembourg but interest income is compensated by interest expenses (back-to-back financing)
Day-1_breakouts-all_Deloitte-2021-MA-Tax-Virtual-Conference.pdf
Corporate Luxembourg Structuring and financing private equity and general Luxembourg law and will in vehicles (and for a Sàrl) to buy back
ogier-structuring-and-financing-private-equity-and-venture-capital-transactions.pdf
4 nov 2010 · Luxembourg participation exemption (incoming dividend and capital gain studies for newly established back-to-back financing entities
Symposium_Luxembourg2010.pdf
recognised that it is most appropriate for back-to-back financing • Bank opinions are discarded as a source of relevant and acceptable benchmarking
TP-of-loans-financial-instruments-November-2018.pdf
Pursuant to Luxembourg income tax law, a Lux Financing TP Rules applicable to Luxembourg transfer pricing rules: all back-to-back intra-group
Luxembourg%20tax%20developments%20summer%202017.pdf