|
The Luxembourg direct tax authorities have recently released a circular that intends to clarify the tax situation of Luxembourg companies that perform intra-group financing activities. The circular does not represent a dramatic change in the tax position of Luxembourg financing companies.
On the opposite, it rather acknowledges in clear and formal terms what has become, for financing companies, what we could consider good tax practice in Luxembourg with respect to:
- the transfer pricing guidelines to be relied on by these companies in order to evidence that the remuneration, and activity as a whole, is adequate and in line with third parties transactions characteristics;
- the procedure to be followed in order to obtain a binding...
|