3 juil 2017 · “back to back loans” will be terminated as at 30 June 2017 The Circular applies to intra-group financing activities where
CY_TaxAlerts_3_7_2017EN_Noexp.pdf
financing activity and evaluation of the compliance with the contractual commitments prior to the final closing • Managing the transaction like credit risk
Changes-to-the-Back-to-Back-Financing.pdf
ing the taxable income in its corporate tax returns 2 3 The concept of hidden dividend A Luxembourg company (LuxCo) performing financing activities
et_-_luxembourg_reshapes_its_transfer_pricing_landscape_-_april_2015.pdf
18 jan 2017 · out group financing transactions refers to any activity consisting of granting loans or (cash) advances to
pwc-TP-Luxembourg-intra-group-financial-transactions.pdf
Undertaking activities of a preparatory or auxiliary nature through the specific activity exemptions Tax structures using back-to-back loans
15_043_International%20tax%20structures%20in%20the%20beps%20era%20_final_web.pdf
30 jui 2017 · For the purposes of this Circular, the term intra-group financing transaction refers to any activity consisting in the granting of loans or cash
Back-to-Back-Tax-Dept-Circular-3-EN.pdf
1 nov 2020 · < back to indexpage Index Transfer Pricing 5 Financial transactions 5 Centralised activities 5 Country-by-country reporting
year-end-tax-bulletin-2020.pdf
to pay their obligations, and to provide returns to their investors 5 6 Financing activities are activities that result in changes in the size
AS_3.pdf
4 nov 2010 · studies for newly established back-to-back financing entities That do not perform activities subject to a business license or
Symposium_Luxembourg2010.pdf
Any activity of granting of loans or cash advances remunerated by interest to related companies, financed by financial means and instruments, such as debentures
transfer-pricing-in-%D1%81yprus.pdf