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On 8 April 2011, the Luxembourg tax authorities issued an additional Transfer Pricing Circular, Circular L.I.R. n 164/2bis. This Circular clarifies the application of Circular L.I.R. n 164/2 (hereafter TP Circular), issued on 28 January 2011 for entities that are mainly carrying out intra-group financing activities, i.e. intra-group lending activities financed by borrowings. Taxpayers who fall within the scope of the TP Circular and who have obtained a confirmation from the Luxembourg tax authorities prior to 28 January 2011 can benefit from it until the end of this year. As of 1 January 2012, such confirmation will no longer be applicable and a new written confirmation can be obtained if the transaction complies with the TP Circular. This article describes the...
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