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Luxembourg - Luxembourg Tribunal’s Decision: Arm’s Length Interest Rate on a Shareholding Loan and Transfer Pricing Documentation – Analysis of Case N° 40348 of 22 October 2018

Country:
Luxembourg
Author:
M. Rasch; A. Cea
Issue:
International Transfer Pricing Journal, 2019 (Volume 26), No 3
Published:
26 April 2019
In October 2018, the Luxembourg Administrative Tribunal decided on a case of hidden dividend distribution. This is an important case because it provides insight on how the Luxembourg tax authorities focus on financial transactions as well as on the obligation to prepare transfer pricing documentation. In this article, the authors discuss the case.
 
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