By Oliver R. HOOR (picture) and Pierre KREEMER,
KPMG Luxembourg
Luxembourg is one of the leading European centers for vehicles investing in international real estate. For tax efficiency purposes, real estate investments structures often involve intermediary financing transactions that fall within the scope of the Transfer Pricing Circular 164/2 of 28 January 2011. This article analyses how Luxembourg real estate structures are affected by these Transfer Pricing rules and the actions required with regards to existing structures.
I. Introduction
Since the early 2000s, Luxembourg has witnessed a significant growth in the development of the real estate industry. There are many ways to structure...
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