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By Oliver R. HOOR and Christophe DARCHE, Atoz *
On 12 October 2016, Finance Minister Gramegna presented the draft law on the 2017 budget which includes a new Article 56bis to be included in the Luxembourg Income Tax Law (“LITL”). The new provision will complement Article 56 of the LITL and provide more guidance on the application of the arm’s length principle under Luxembourg tax law. This article provides an overview of Article 56bis of the LITL and analyses its impact on the Luxembourg transfer pricing landscape.
Introduction
Luxembourg companies may enter into diverse commercial and financial transactions with associated companies. For Luxembourg tax purposes, the terms and conditions agreed to in respect of intra-group...
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