On 27 December 2016, the Luxembourg tax authorities issued revised guidance on intra-group lending activities financed by borrowings. Circular L.I.R. 56/1-56bis/1 has been aligned with Actions 8 to 10 under the OECD BEPS Project and replaces the previous Circulars L.I.R. 164/2 and 164/2 bis from 28 January 2011 and 8 April 2011 respectively.