28/12/2016

On 27 December 2016 the Luxembourg Tax Authorities (Administration des contributions directes) issued Circular Letter L.I.R. – N° 56/1 – 56bis/1 (the “New Circular Letter”) on the tax treatment of companies engaged in intra-group financing transactions.

The New Circular Letter replaces the previous circular letters LIR N° 164/2 and 164/2bis dated 28 January and 8 April 2011 in order to render the Luxembourg transfer pricing rules compliant with the revised Chapter I Section D of the OECD Transfer Pricing Guidelines.

The main amendments may be summarised as follows:

• replacement of the lump sum determination of the equity at risk of 1% capped at EUR 2 million on a case-by-case analysis;

• enhancement of the content of the transfer pricing reports;

• amendments to the minimum substance requirements;

• simplification measure for intra-group financing companies acting as intermediaries; and

• amendments to the list of information to be provided for advance pricing arrangements.

> Click on the link below to read the full details of the New Circular Letter.

YOU MIGHT ALSO WANT TO DISCOVER

21/01/2021
Anti-money laundering and counter terrorist financing – mandatory survey due in March 2021

We would like to remind you that on 15 February 2021, the CSSF will launch its annual online survey on the fight against money laundering and terrorist financing for the year 2020 (the “AML/CFT Survey”).

Read More_
Arendt We Live - Digitalisation and cybersecurity, an unhappy marriage or an essential partnership?