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By Emilien LEBAS, Partner, Head of International Tax, Tax controversy dispute resolution leader Valentine PLATEAU, Manager, International Tax, KPMG Luxembourg
On 17 April 2025, the Luxembourg administrative Court (Cour administrative, 17 avril 2025, n° 50602C) (the “Administrative Court” or the “Court”) was called upon to take position on the qualification of interest-free loan payables (IFLs) granted to the taxpayer by its indirect shareholder for direct tax purposes.
Summary of the case
In October 2014, the taxpayer acquired two shareholdings and planned to establish a branch in Malaysia to which the participations would be allocated. In August 2015, the taxpayer requested a tax ruling from...
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