Publications

On 8 April 2011 the Luxembourg direct tax authorities issued Circular L.I.R. 164/2 bis (Circular Bis), which clarifies the conditions for application of a previous circular of 28 January 2011 (the Initial Circular) relating to the tax treatment of intra-group financing transactions. This development can be seen in the light of the desire of the Luxembourg tax authorities to reiterate the alignment of their APA practice with OECD transfer pricing principles.

Clifford Chance has prepared a briefing paper outlining these clarifications.