Luxembourg - Hidden Capital Contributions in Luxembourg -Clearing the Mist
- Philippe Neefs; Oliver Hoor
- European Taxation, 2009 (Volume 49), No 5
- 1 May 2009
The shifting of advantages motivated by the shareholding relationship to a company remains an obscure issue and the basis for the requalification of transactions into hidden capital contributions. Insofar as the concept of hidden capital contribution in Luxembourg is scarcely covered, this article aims at defining its main traits and clarifying its tax consequences. Consequently, descriptions of the concept and the resulting Luxembourg tax consequences are provided.