Luxembourg - Transfer Pricing Guidance Issued on Intercompany Financing
- B. Sigurdardottir; M. Rasch; C. Laplume
- International Transfer Pricing Journal, 2011 (Volume 18), No 3
- 13 May 2011
On 28 January 2011, the Luxembourg tax authorities issued Circular L.I.R. n° 164/2 providing guidance on intra-group lending activities financed by borrowings. The Circular clarifies the tax treatment of intercompany financing and determines the taxable result in accordance with OECD transfer pricing principles.